Your gluten free accreditation audit The Gluten free Audit Standard is a copyright document. All rights reserved. No part of this publication may be reproduced in any form (including photocopying or storing it in any medium by electronic means) without written permission. Applications for permission should be addressed to Coeliac UK in the first instance. Information emanating from Coeliac UK is given after the exercise of all reasonable care and skill in its compilation, preparation and issue, but is provided without liability in its application and use.
Revision history Version Revision Date Purpose of revision 1 August 2013 Initial publication 2 February 2014 Revised guidance for no. audits for multiple sites 3 November 2014 Revised guidance for no. audits for multiple sites 3.1 November 2015 Change of contact details 4 September 2016 Revised grading structure, updated logo, updated in line with EU legislation changes, amend to clause 6.1 4.1 January 2017 Change of contact details and prices 4.2 January 2017 New branding 2
Contents Revision history... 2 1 Background... 4 1.1 The law on gluten free... 4 1.2 Why have a gluten free audit?... 5 1.3 I have more than one venue, how many audits do I have to have?... 5 1.4 How much does the gluten free audit cost?... 6 2. The audit process... 6 2.1 Preparation for the audit... 6 2.2 Audit Booking... 6 2.3 Audit Process... 6 2.4 Non-conformances... 7 2.5 Corrective Action Process... 8 2.6 Grading Process... 8 2.7 What happens if my business fails the audit?... 8 2.8 Audit Report... 8 3 Confidentiality... 9 4 Complaints and Appeals... 9 5 Coeliac UK Gluten free Audit Standard... 10 3
1 Background Coeliac disease (pronounced see-liac) is a serious illness where the body s immune system reacts to gluten found in some foods and attacks the gut. This is known as an autoimmune disease. Dermatitis herpetiformis is the skin manifestation of coeliac disease. There is no cure; this is a lifelong condition for which the only treatment is a strict gluten free diet for life. Coeliac disease is not an allergy or intolerance. People with coeliac disease aren t faddy eaters the gluten free diet is their treatment. If someone with coeliac disease repeatedly eats gluten or their condition goes untreated, they will be damaging their gut and putting themselves at risk of osteoporosis and a rare form of small bowel cancer. 1 in 100 people have coeliac disease. Although many are still not diagnosed it is improving rapidly, which means the gluten free market is increasing as people try to maintain their lifestyle as they adapt to the diet. 1.1 The law on gluten free When producing gluten free dishes you need to have an understanding of the law to make sure you are compliant. Commission Implementing Regulation (EU) 828/2014 covers the labelling of gluten free food. Legislation around the use of the term gluten free has been in force since 1 January 2012 and applies to foods served in catering establishments as well as pre-packaged food. Gluten free is a term protected by the law and applies only to food which has 20 parts per million (ppm) or less of gluten. The law does not specify how to achieve the standard set out for gluten free. But by working with Coeliac UK, and the advice provided by Trading Standards and the Food Standards Agency we can help you ensure that your dishes meet the requirements of the law on gluten free. 4
1.2 Why have a gluten free audit? Getting your dishes to gluten free status will mean you are using a recognised and reassuring phrase which your consumers already know. It is worth going the extra step to get to this level if you can. This standard is designed to be used by food businesses preparing non pre-packed foods. It will give an independent expert review of your system with consultative input for recommendations of improvement and acting as additional due diligence evidence to support technical functions on site. The gluten free audit is mandatory for all caterers applying for GF accreditation. 1.3 I have more than one venue, how many audits do I have to have? The number of audits required for companies with 12 sites or more, where processes, menus and training are consistent across sites, is calculated on a square root basis. The square root of the number of venues you have rounded to the nearest whole number is the number of audits you will be required to have. You can choose to have more audits if you would prefer to audit a greater number of your venues. The number of audits to be carried out is subject to guidelines available at: www.coeliac.org.uk/auditguidance/. Example audit numbers are shown in the table below: Number of sites Number of audits 1-4 1 5-9 2 10-12 3 50 8 100 10 150 13 300 18 5
1.4 How much does the gluten free audit cost? Each gluten free audit costs 180 +VAT as a standalone audit. For those caterers who also have their food safety audits with NSF a bolt on audit can be arranged at a reduced cost. For more information on the reduction in fee, please contact: Chris Harrison via Chris.Harrison@coeliac.org.uk. 2. The audit process 2.1 Preparation for the audit Your company should ensure that they have read and are familiar with the requirements of the Coeliac UK Gluten free Audit Standard in advance of the audit and are prepared for it. Guidance on the interpretation of the Standard can be provided by Coeliac UK and NSF. 2.2 Audit Booking All enquiries and requests for audits should be directed to Chris Harrison at the Coeliac UK Head Office. Telephone 01494 796727, email Chris.Harrison@coeliac.org.uk. 2.3 Audit Process Audits will usually take 2 hours (1hour for a bolt on audit) and consist of the following elements: an opening meeting to establish anticipated outcome for the day discussion and review of the gluten free section in Hazard Analysis and Critical Control Points (HACCP) plan and specification(s) applicable to product(s) supplied to the customer with any third party requirements the Coeliac UK Gluten free Audit a closing meeting including problem solving initiatives and corrective actions that need to be addressed in order to close the audit. All sections of the Standard will be assessed and detailed notes are made of the business s ability to comply with the Standard. These will be used as the basis for the audit report. 6
Should a clause of the Standard not be met, the auditor will consider the nature and significance of this; it will be discussed with the auditee at the time and non-conformances will be reviewed at the closing meeting. 2.4 Non-conformances There are three levels of non-conformance which can be raised during the gluten free audit. Critical There are elements of the Standard that are linked with absolute requirement in order to produce safe or legal food. Failure to comply with any of these requirements would represent a Critical non-conformance, meaning there is a severe likelihood of serving gluten-containing food labelled as gluten free. Examples would include: serving a gluten-containing dish labelled gluten free a severe risk of cross contamination e.g. gluten-containing ingredients contaminating gluten free ingredients in storage. A site gaining a Critical non-conformance would be considered to have failed the audit and will require a full re-audit within 14 days. If there is a substantial failure to meet the requirements of a clause / sections of the Standard a non-conformance may be raised, there is a likelihood of serving glutencontaining food labelled as gluten free. Examples would include: HACCP system not established Risk controls not specified in production Failure to fully meet the requirements within a clause or section of the Standard. Contamination with gluten is unlikely however the business cannot demonstrate fully adhering to the requirements of the GF Standard. 7
Examples would include: Incorrectly completed / missing training records Business operator not having knowledge of the relevant legislation. 2.5 Corrective Action Process The final grade will only be confirmed following successful completion of corrective actions to close out non-conformances that must be submitted to Coeliac UK within 14 days of the audit. Corrective actions will be submitted online using the NSF online system. 2.6 Grading Process The Standard utilises a grading system which is determined by the number and severity of non-conformances which are highlighted during the audit. Critical non-conformances are an automatic fail, major non-conformances score 3 points and minor non-conformances score 1 point. Grade Points A 0-3 B 4-6 C 7-9 10 or more points or 1 Fail critical 2.7 What happens if my business fails the audit? In the event of a fail from either 10 or more points or one critical, a re-audit will be required within 14 days. You will be required to pay for the initial audit as well as the re-audit. For any failed bolt-on audits, a full re-audit will be required. Re-audits are charged at the same price as initial audits - 180+VAT. 2.8 Audit Report The audit report will be produced following the audit and this will comprise the following: 8
details of the audit, audit date, site address, management representatives, gluten free dishes produced, overview of the company as well as the final result achieved an executive summary outlining what is going well as well as areas for improvement details of how the site complies with the Standard is given in tabular form a list of all non-conformances identified against the Standard is given. 3 Confidentiality Information relating to the customer s business including details of original recipes and processes, audit reports and associated documentation will be treated by Coeliac UK and NSF as confidential (unless disclosure is required by law). No information is released to third parties without the prior consent of the customer. 4 Complaints and Appeals Coeliac UK s audit partner NSF operates a documented complaints and appeals procedure as part of its Quality System. Full details are available on request. Complaints and appeals must be made in writing by named person(s) within 30 days and addressed to: Chris Harrison Coeliac UK 3 rd Floor Apollo Centre Desborough Road High Wycombe Bucks HP11 2QW 9
5 Coeliac UK Gluten free Audit Standard 1.0 HACCP and GLUTEN FREE LAW Grade In accordance with Regulation (EC) No. 852/2004 Article 5 - Hazard analysis and critical control points The process flow and critical (HACCP) control points (CCPs) have been provided Food business operators shall The HACCP Plan covers:- put in place, implement and i. products supplied to maintain a permanent procedure specified client (s) 1.1 or procedures based on the ii. gluten free management HACCP principles. This and cross contamination essentially means operating a iii. all ingredients, processing food safety management aids and packaging. system. iv. effective monitoring The site has a documented Food Safety Management procedures at critical control points. system or HACCP Plan which addresses the gluten hazard. Commission Implementing 1.2 Regulation (EU) 828/2014 - Gluten free law - food business able to demonstrate knowledge The Coeliac UK accreditation pack is an acceptable tool. of gluten free legislation. Coeliac UK or internal Reference Material documentation on gluten free Staff know where to find preparation are acceptable 1.3 information about preparing tools. Recipe cards and gluten free foods. specifications showing ingredients and processes for preparation of GF meals. 10
2.0 TRAINING You should provide training for all staff on communication, 2.1 preparing and serving of gluten free foods. Is knowledge verified? Training records for the preparation of gluten free dishes 2.2 are retained and signed. Are staff trained not to guess if unsure of food ingredients or GF processes? Records are available for all relevant staff trained. Grade 3.0 COMMUNICATION Site is able to demonstrate system in place to provide 3.1 customer with clear information relating to the gluten status of all foods served. Demonstrate system of communicating changes in 3.2 gluten status of ingredients, menu changes or other factors affecting serving GF food. Business can demonstrate effective system of 3.3 communication between front of house and back of house for GF foods. Info available for all GF dishes (ingredient information available) either on menu, leaflets, recipe cards, verbal. Staff meeting, daily briefings, memos for ingredient change notification. Verbal instructions or written instruction of GF requirement on docket, till system able to identify GF requirement. If online ordering available, communication system in place between online order and kitchen production. CRITICAL CRITICAL Business encourages customers 3.4 to discuss GF requirements with Signage/website/menu/verbal. staff. 11
Menu complies with law on GF 3.5 and guidance from Food Standards Agency. 4.0 SUPPLY CHAIN CONTROLS 4.1 Reputable Suppliers are used. Is there a system in place to monitor incoming products and ingredients to ensure any changes in gluten content are 4.2 identified? Do suppliers notify the restaurant of any ingredient changes? If no, is the system managed effectively on site? If contingency/alternative supplier is used then there is a 4.3 system in place to record ingredient details and presence of gluten. GF menu must be accurate. It must not include contradictory disclaimers. GF menus must not include descriptions relating to the statement No gluten-containing ingredients (NGCI). Refer to menu guidance. Business can provide evidence of supplier assurance/accreditation (certificates from third party or most recent Local Authority visit report). Caterers should be aware of food fraud in the supply chain and be vigilant when choosing suppliers. Check receiving documentation. Are there records to show incoming ingredients are checked for gluten status. Method of supplier notification is stated i.e. email, fax, letter. Procedure includes how supplier triggers notification. On questioning, business should be able to demonstrate that they check ingredients, is gluten free stated on contingency purchase? If contingency purchases not allowed, staff must know that this is the case. Grade CRITICAL 12
5.0 GOODS IN and STORAGE Records of checks done on incoming goods showing any 5.1 cross-contamination risk and/or spillage. Frequency, method and measurement criteria are stated. To be documented on receiving documentation. Grade CRITICAL if gluten free ingredients visibly contaminated or risk of 5.2 Are storage conditions suitable to ensure product identity and Gluten free material is stored in clearly marked containers or dedicated shelves above contamination severe. e.g. open ingredients not stored correctly. prevent cross contamination. gluten containing material. If best practice not followed i.e. sealed/unopened containers of gluten free food stored below glutencontaining food. Business can demonstrate control for accidental spillage of Spillage is cleaned-up 5.3 gluten ingredient e.g. wheat immediately using single use flour, whether in storage or cloths. production. Training in handling, storage, Training method is stipulated segregation and accidental i.e. how it is done and 5.4 spillage of gluten ingredients for staff. Records kept and content. The records cover all staff available. involved in handling goods inwards. Where raw material is debagged or de-boxed then it 5.5 Once opened, all products decanted into clearly labelled lidded containers. is done so into lidded and labelled/easily identifiable containers. Following storage, the containers are appropriately cleaned. 13
6.0 PREPARATION AND COOKING Preparation area of GF items designed to minimise cross 6.1 contamination risks. Work flows identified avoiding potential cross contamination issues. e.g. time, distance, equipment. Grade workflows are not designed to minimise contamination risk, likely to cause potential for cross contamination. workflows are designed to minimise contamination risk but could be improved to make processes easier to follow for staff. CRITICAL if gluten- System in place to ensure Could be refer to substitute containing ingredients 6.2 ingredients used to prepare GF food are checked for gluten checklist, current packaging, and ingredient information identified absence before use. on file. if best practice not followed CRITICAL if contamination during preparation/cooking clearly visible or the risk of Cross contamination risk or i.e. frying oil, toaster, contamination is severe. 6.3 preparation/cooking method is controlled during preparation basting, griddling/grilling, see guidance on policy notes if best practice is not and cooking (see guidance). of the audit. followed which could lead to cross contamination, i.e. separate containers and utensils are used but not clearly labelled. Waste (including Unused GF products clearly contaminated ingredients) is 6.4 labelled and securely covered to labelled and physically allow identification for next shift. moved away from the area. 14
6.5 Hot holding and cold holding service conditions are suitable to ensure product identity and prevent cross contamination. GF dishes that are held in a holding service must be clearly distinguishable. 6.6 Probe thermometer controlled to prevent cross contamination of GF and gluten containing foods. Separate probe used, or if not possible it should be cleaned between uses using probe wipes. Separate utensils, clearly Hot holding and cold holding labelled, are used for GF 6.7 buffets -Separate utensils are foods. System must be in provided for all dishes. place to ensure that the correct utensils are used. 7.0 GOOD HYGIENE PRACTICES Cleaning schedules account for areas where GF 7.1 ingredients/dishes are prepared/stored. Clean utensils/surfaces used for 7.2 GF preparation. You should use either commercial, domestic dishwashers or effective manual 7.3 washing practices (hot water, detergents, rinsing) to remove gluten from food contact surfaces. Food handlers wash hands in between preparation and use of 7.4 gluten containing and gluten free products. Evidence of best practice cleaning methods used: clear debris, use degreaser and disinfectant or sanitiser. Use single use cloths. Either dedicated utensils, clearly labelled, or clean utensils used for GF preparation. Evidence of cross contamination noted i.e. food handler not washing hands after preparing food containing gluten and then preparing GF dish. This is to 15 Grade CRITICAL
be scored as critical. Clean protective clothing is available and staff know where to find it. Clean staff 7.5 Staff clothing is suitable for preparation of gluten free food. clothing may not be required in every site, dependant on contamination risk, e.g. clothing covered in flour would present a contamination risk. 8.0 Quality Assurance/ VERIFICATION Grade Inspection of the systems, procedures, documentation. If testing forms part of the 8.1 Internal audits/risk assessments undertaken covering gluten free production. risk assessment test certificates should be available. Testing must be validated and using the recommended method of analysis used R5 ELISA Mendez method. 8.2 Any customer complaints should be logged and investigated with reference to procedures in place. Score down if customer complaints are not logged. 9.0 MANAGEMENT COMMITMENT Company policy established and signed which includes gluten free claims. It states the 9.1 Company s commitment to gluten management. Score down if written policy not in place. 16