FAQs On GFCO’s Grain Count Requirement
On June 1, 2018, GFCO sent notice to all of our Brand Owners and manufacturing Plants that, beginning January 1, 2019, all whole unprocessed grains, beans, seeds, pulses and legumes sold bearing the GFCO logo must contain no more than 0.25 gluten-containing grains per kilogram, in addition to meeting the 10 ppm threshold.
Since the release of that notice, we have received several questions about its meaning and implementation. The following are some of the most frequently asked questions about this new requirement, with answers provided by GFCO.
What does the “0.25” refer to? What is being measured?
This new threshold is measured in the number of wheat, rye or barley grains present within a kilogram of the gluten-free grain, seed, bean, pulse or legume being sold. This number is obtained by examining the gluten-free grain for the presence of inadvertent wheat, rye or barley grains, and determining the average number of these grains per kilogram of gluten-free product. This threshold can also be expressed as “no more than 1 gluten-containing grain per every 4 kg of gluten-free grain”.
What does “unprocessed” mean?
Unprocessed means that the commodity has not been processed beyond basic cleaning, washing, dehulling, deshelling, heating to enhance stability (not for cooking), or drying for storage.
What is meant by “visual inspection”? For example, do the grain counts have to be done only by our staff?
For the purposes of this GFCO requirement, “visual inspection” means the identification of wheat, rye or barley grains within a gluten-free grain, as confirmed by the human eye. This does not mean that all of the sorting and identification have to be done entirely by people, although it can be. Properly validated optical and mechanical methods can also be used to sort grain samples and isolate any potential contamination by wheat, rye or barley. The final identification of any grains flagged by these methods should be made by trained personnel.
Does this new requirement apply to my incoming ingredients?
No. At this time, GFCO is only placing this requirement on manufacturers who sell whole, unprocessed grains, beans, seeds, pulses and legumes bearing the GFCO logo.
Does this requirement apply to spices?
No, whole-seed spices are not expected to meet this new requirement.
Does this requirement include popping corn?
The requirement will apply to bulk popping corn sold for further packaging or processing, but not to popping corn that sold to consumers in any retail packaging, whether seasoned or unseasoned.
What records will GFCO expect to see, to show that we are meeting this new requirement?
In addition to the testing log you have been using to track your in-house gluten testing, or the test results you receive from an independent laboratory, GFCO auditors will also want to see records of the grain counts you have performed on each lot of whole grain, seed, bean, pulse or legume that is sold bearing the GFCO logo. These grain counts should be done using a statistically valid sampling plan, and should show that the average contamination is at a level below 0.25 gluten-containing grains per kilogram of the gluten-free grain, or 1 whole gluten grain per 4 kg of gluten-free grain.
If you have any questions about your company’s certified products, and whether this new requirement applies to any of them, please contact GFCO and we will review your product list.