I have had many people contact me regarding the Applegate Gluten-Free Chicken Nugget recall namely because they could not understand how something like this could happen to a product that carries the Gluten Intolerance Group’s (GIG) Certified Gluten-Free certification seal.  First off, I want to state that I am a huge supporter of advocacy groups like GIG who help raise awareness for Celiacs like myself.  They do great work and this post is not meant to belittle the work that they do but rather to question one part of that work that might be outside of their operational depth.

I too was a bit taken aback that something like this could happen – particularly to an item that carried the certified GF designation.  In this recall case, apparently the wrong products made it into the wrong packages (approximately 1,572 pounds of chicken, that’s 3,144 packages).  Here’s some of Applegate’s explanations from their FAQs for the recall (the full FAQs can be viewed here):

How much of this product is out in the marketplace?
We have confirmed that 3,144 packages of Applegate Naturals Gluten-Free Chicken Nuggets are potentially affected. The shipment of this product has been tracked and all retailers with affected product have been notified.

How did the problem occur?
During the packaging process, the product containing gluten was packed in boxes that are labeled as gluten-free. This was an isolated issue and did not impact any other products.

How did Applegate know there was a problem with the recalled product?
The problem was detected by a consumer who is familiar with the product and noted a color difference. This product was labeled with a Lot Code 210864 and a “Best Before” date of August 28, 2013.

So essentially the products in question made it through the entire production and packaging processes entering the market without anyone from Applegate even picking up on the mistake.  According to both Applegate and the USDA’s Food Safety and Inspection Service (in their Class I recall notice) it was a consumer who noticed that the products in question did not look the same as the gluten-free variety they were familiar with.

While I realize mistakes happen, it is the fact that the products made it to market that I find most difficult to understand – particularly since the products in question carry a rather large certified gluten-free logo on the front of the box.  Clearly consumers have certain expectations when they choose to purchase a product with the certified gluten-free logo.  So I began to wonder just what was involved in the GIG gluten-free certification process.  I knew that it entailed the evaluating and testing of prospective manufacturers and their products but after this incident began to question the rigor of such certification programs.  I looked through their materials on their Web site but their The Complete Guide to Certified Gluten-Free Products, Companies and Manufacturers was still pretty broad with only two pages out of 100+ actually discussing the certification process and the remainder allocated to showcasing companies and products already certified.  I still was unclear as to the true scope of the whole certification process – with the main question being is it the entire process that is certified or just the products?

I decided to  e-mail Cynthia Kupper, GIG’s Executive Director, the following questions to better understand the entire certification process:

1. Could you please speak to the scope and rigor of your certification process?
2. Does your certification process include the manufacturing, product testing, and packaging components?
3. What steps do you take (or will you now be taking) with certified manufacturers who experience a recall?
4. Are certified companies held accountable for such errors and will there certification be re-evaluated or revoked?
5. Will you be changing or enhancing your certification process now that a recall has occurred?

I have to say that within a couple of hours of sending my e-mail I received a response from Ms. Kupper stating that she responded to a discussion post I had started in a Facebook Group that pretty much answered the questions I have posed.  Her response was as follows:

GFCO, a certification program run by GIG, has very strict standards in place. We use auditors with at least 3-5 years doing food safety audits in manufacturing companies.

GFCO, as with all certification programs of any type, review complete processes, including the GMP and HACCP programs. This looks at all levels of production, raw material procurement and handling, cleaning, packaging, etc. GFCO reviews risks of mistakes and will require changes in order to certify a plant or product. If a company does not agree with the requirements for testing, audits and other required changes, certification is not issued.

No certification program has an auditor observing production at all times. Kosher certification companies probably do the most audits, outside of the USDA. But even then, the USDA inspector is not observing the production lines during the entire process (and they have offices in the plants).

In order for GFCO to do this type of monitoring, we would have to hire thousands of auditors and pay them to be in a plant continuously. This is impractical and would run the cost of GF foods to an unreasonably high price.

This was a company issued voluntary recall. Meaning they contacted the regulatory agencies to inform them of the mistake and issued the recall. Corrective actions have already been implemented.

Certification is voluntary. A company that chooses third party certification programs generally do so to build consumer confidence and to set themselves apart from the competition. GIG takes certification very seriously. We contact the companies with recalls routinely to assure that we agree with their corrective actions, and to determine if GFCO needs to also take additional actions, such as increased audits and testing.

While I appreciate that no certification program is 100% foolproof I do have to question the rigor of voluntary types of certification programs like GIGs.  Are they better than nothing – sure.  Let’s face it, companies are paying GIG to have their products certified so it is a revenue stream for the organization.  In its 2010 Federal 990 filing, the GIG certification program was listed as generating more than $500,000 in revenue.  I understand that there are expenses incurred for the certification program but nonetheless it shows that companies are in fact paying for the voluntary privilege of certification.  We as consumers are also paying a premium for certified gluten-free products so I do not think it is too much to ask that those items and their manufacturing processes (from start to finish) are stringently overseen.  My only additional question to GIG would be: How many inspectors does GIG have for its certification process and do these inspectors visit each facility at least once a year?

Applegate’s resolution for helping to ensure this does not happen again is perhaps what worries me most (excepted from their FAQ site):

How will Applegate prevent this from happening in the future?
We have carefully evaluated every step in the processing and packaging of this product. As a result, we have identified and implemented the following steps that will provide added assurance against a similar incident occurring in the future.

We have improved our label verification process. A sample of each of our gluten-free retail boxes is now verified against a printed image of each box and all employees who process or pack the product have been fully educated on this improved process.

If more than one product is packed on the same line on the same day, we will document and verify that all packaging from the prior run is removed from the area before starting a new product run.

Quite honestly I would have expected that the above measures to already be in place in a gluten-free certified product – particularly one produced in a shared (both GF and non-GF) manufacturing facility.  Getting the correct products into the correct box should be a minimal expectation for a certified company.  The most worrying part of all this is that thousands of boxes went unnoticed and made it into consumers hands.  I completely understand that mistakes do happen but this was a case of 3,144 mistakes that had a consumer not noticed, could have ended quite differently if the packages were consumed (at the time of this post the USDA indicated that no other complaints had been reported).

As with most things gluten-free it still comes down to a personal comfort level when purchasing and consuming gluten-free products.  Will I still purchase GIG certified gluten-free items?  Yes.  I mean with no federal gluten-free standards at least some level of monitoring is better than none.  Do I think that perhaps GIG is operating a bit beyond its capacity?  Yes.  I am sure that they have the best intentions with their certification program but perhaps it has grown beyond what they can effectively manage to ensure that program rigor is maintained.  I fully understand that when eating out or purchasing products, unless it is a dedicated facility or establishment, that things can go wrong.  As a Celiac and food allergic consumer I can only take a leap of faith and make the best personal decisions I can when it comes to food – particularly when it comes to packaged products.

Will I purchase Applegate Gluten-Free products?  Likely not in the near future.  I just can’t get past the fact that so many thousands of products made it into the marketplace unbeknownst to Applegate.  I do appreciate the fact that steps are being taken to prevent things like this from happening in the future but really feel they dropped the ball on this one – which is a shame because I usually have six or seven boxes in my freezer at all times and I have been a loyal fan for years.

Please Note: To leave a comment on this post, click on the post title above, then scroll-down to the bottom of the post.  Or if you are already on the post, scroll-down to the comment box following the comment string.   I’m working on making this more intuitive in a future site update coming soon.