Coeliac Customer and a Shared Bakery Mixer
A bakery makes 12 gluten-free loaves each morning alongside 200 regular wheat loaves. The gluten-free range is stored on the top shelf of a shared rack and labelled 'GF'. The bakery has one planetary mixer; staff scrape it down between batches but do not dismantle the whisk or clean the bowl with a validated method. A customer with coeliac disease phones to order a gluten-free birthday cake. The manager says the sponge is made with 'gluten-free flour' and baked in the same oven as wheat bread, and the cake is decorated on a bench that was wiped with a damp cloth after handling wheat flour. The bakery also uses a shared sieve for icing sugar. The customer asks for a written assurance that the cake is suitable for coeliac disease. The bakery is not approved for gluten-free certification and has no allergen matrix. Staff received allergen training six months ago.
1. What should the manager tell the customer about the birthday cake, and why?
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The manager should not give a written assurance that the cake is suitable for coeliac disease. Coeliac disease requires gluten to be controlled to very low levels (typically no more than 20 mg/kg, or 20 ppm, for a gluten-free claim), and the bakery cannot demonstrate that level. The shared mixer, whisk, sieve and oven, plus flour dust and the damp-cloth wipe, are all routes for gluten cross-contact. A 'gluten-free flour' ingredient is not enough if the finished product is contaminated. The honest answer is that the bakery cannot guarantee the cake is gluten-free and the customer should be advised not to rely on it. The bakery can offer a product without a gluten-free claim, with clear allergen information, or decline the order. It should not use a 'may contain gluten' label as a substitute for proper controls, and it should not accept the order on a verbal assurance that staff will 'be careful'.
2. Set out the controls needed before any product is sold as gluten-free.
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Before selling any product as gluten-free, the bakery needs an allergen risk assessment and documented controls:
- Separate or dedicated equipment (mixing bowl, whisk, sieve, bench, tins) or a validated cleaning method between wheat and gluten-free batches.
- Production scheduling: make gluten-free items first, before wheat flour is opened, and cover or store them separately.
- Control flour dust; avoid using shared sieves and cloths; use disposable paper and a validated cleaning regime.
- Supplier specifications for all ingredients and a finished-product allergen matrix.
- Staff training on coeliac disease and cross-contact, with refresher records.
- Verification through finished-product gluten testing or swabs, plus record review. The claim should only be used once the controls are validated and the HACCP plan includes allergen cross-contact as a significant hazard.
3. What should be done with the 12 loaves already labelled 'GF' this morning?
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The 12 loaves already labelled 'GF' should not be sold as gluten-free. They were produced under the same uncontrolled conditions, so the label is not supported. The bakery should hold or withdraw them, remove the GF claim, and either sell them without a gluten-free claim or discard them. If any have already been sold, the bakery should contact those customers and correct the claim; if the risk assessment shows a serious risk to coeliac customers, it should follow its incident and recall procedure. The manager should record the decision, the reason and the quantity affected, and review the production records. This is also a trigger to check whether previous GF batches were sold without verification.