Going Gluten-Free: Examining the Manufacturing Process: Identifying High-Risk Points


Questions include how to prevent cross-contamination and how to comply with FDA’s gluten-free rules.

Despite a manufacturer’s choosing and sourcing only non-gluten–containing ingredients, a number of opportunities exist for gluten contamination across the production process.

“Ingredient sourcing is the most common introduction of cross-contamination,” says Larry Brauer, product certification manager, Celiac Support Association’s Recognition Seal and Gluten-Free Certification Program. “Processing equipment and storage procedures should be evaluated” for their potential to cross-contaminate.

Tricia Thompson, MS, RD, founder of Gluten Free Watchdog and author of The Gluten-Free Nutrition Guide and other books, lists such seemingly unlikely raw ingredients as herbs, botanicals, fillers (starch), oat fiber, wheat grass, barley grass, and rye grass among those with potential for gluten contamination by the time they arrive at a processing plant. She adds that “anything grown in the ground” can become contaminated in the field during crop rotation or via an errant wheat, barley, or rye plant; during harvest from the use of shared equipment; during transport from shared trucks or rail cars; at the processing plant from shared elevators; etc.  

And then, “depending on the products produced by the manufacturer and whether there is a hazard analysis and critical control points [HACCP] plan in place for the handling of allergens and gluten, contamination may occur in the facility,” she says.

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