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Reminder
All GFCO clients that produce whole-grain products, such as flax, hemp, lentils, buckwheat, and oat groats, which are sold or shipped as their “product” either for further manufacturing, or for retail sale, must perform visual examination of each lot of these materials for gluten-containing grains prior to their leaving the plant. This is in addition to any assigned antibody-based testing. The process for visual examination is provided in the GFCO Manual, and validation of the sampling plan was published in the Journal of AOAC International in 2018.
The basic process is to take a minimum of twenty samples from throughout the lot/batch of whole grain material. Each sample should be, or should be reduced to, 0.5 kg. Each of these twenty samples should be spread out, one at a time, on a surface and inspected for the presence of gluten-containing grains (GCG). GCG include wheat, rye or barley, and perhaps oats if your product is going to a country where oats are considered a gluten source. Record the number of GCG seen in each of the twenty 0.5kg samples. When you are done examining all twenty samples, add up the number of GCG that were seen. In order to meet the GFCO requirement, you may see a total of 2 GCG across all twenty samples. If you see 3 or more GCG, the lot cannot be sold as certified. This sampling plan works across any lot size, from single bags to multiple truckloads.
The key to accurate visual examination is being able to take samples from throughout every part of the lot. You do not want to take samples just from the tops of truckloads, totes or bags. Samples must be taken randomly from throughout the lot or batch, so taking them as the grain is being moved often provides the best opportunity for this. If samples are taken from static containers (trucks, totes, bags), then proper sampling equipment that allows samples to be collected from the top to the bottom of the container is needed, and samples need to be taken from the beginning to end of the lot.
Proper sampling for visual examination often means that it’s easier to take samples at grain receiving, rather than trying to take them when they are leaving the plant, and either is acceptable. Sampling at receiving will also let you perform the process once for the incoming lot/batch, and avoid the need to sample from each outgoing lot/batch that may come from a single incoming shipment.
New Requirement
GFCO is now requiring that clients who must perform visual examination on whole grain products submit their visual examination records along with their other testing data at the end of each calendar quarter. GFCO auditors have been reviewing this data on-site since the visual examination requirement was implemented in 2018, but we are now asking that this data also be submitted to testing@gluten.org. We will expect to see these records with the next quarterly testing submissions, which will be due July 10, and all submissions thereafter.
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