Applegate Recall and GF Certification. My Two Cents.

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.

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59 responses on “Applegate Recall and GF Certification. My Two Cents.

  1. Jaimie says:

    I always placed faith in the GF certification seal but will now seriously have to re-think what it really means. The recent recall and both parties lack of transparency speaks volumes.

  2. Alex says:

    How something like this could happen boggles my mind. I understand that accidents happen but these went unnoticed and the proposed after the fact “solutions” should have been in place prior.

  3. Stephanie says:

    Really unbelievable.

  4. Susan says:

    Wow, think like this really make you think. Shame it takes something like this to make us question what’s going on.

  5. Donna says:

    I find it disturbing that Applegate missed the problem packages. Thank goodness that consumer noticed something was up and said something.

  6. Sara says:

    This whole thing makes me angry. As a mother of a child with Celiac I have certain expectations when purchasing certified products and find it hard to understand how something like this could have heppened.

  7. Jo says:

    Thank you for the post. This is yet another reason why I choose to only eat what I prepare. Pre-packaged items, certified or not, are not foolproof.

  8. John says:

    Yet another example of an organization operating where they have no business. How can something be certified gluten-free when there are no federal standards even defining what that means? Seems like a whole lot of smoke and mirrors to me.

  9. Gloria says:

    Very surprising. Getting the correct products into the correct boxes seems like certification 101. Too little too late from Applegate.

  10. Rita says:

    Like you said, it is better than nothing, but how much better remains to be seen. Though when things like this happen it makes you think.

  11. Larry says:

    Interesting post. Kind of sounds like no one really wants to address that there was a problem before this recall happened. I’m definitely interested in knowing just how often sites get inspected because there are a lot of companies in the U.S. and abroad that use the certification. Seems dauting that everyone gets a visit at least once a year.

    • Gluten Free Mike says:

      I completely agree and my point exactly. Companies are paying a lot of money for GIG’s “expertise” and something as basic as double-checking products made on a shared line (GF and non-GF) should have been at the top of their recommendations.

  12. Rose Anne says:

    Really makes you think what would have happened had that person not alerted the company.

  13. Deborah says:

    I actually had some of the products in question in my freezer. Really scary to think that I could have gotten glutened from a product I had come to trust. It will take some time to regain that trust.

  14. William says:

    Just goes to show we can never to too complacent when it comes to packaged foods. You just never know.

  15. Andrea says:

    I really hope that other companies take this as a real learning lesson to become more proactive in their handling of their products.

  16. Nichole says:

    Really unbelievable. Love how both GIG and Applegate defend the effectiveness of their programs. Um, seriously?

  17. Jane says:

    Yet another reason we need to have federal standards for GF products. Why is the U.S. dragging its feet?

  18. Allison says:

    I am going to give Applegate the benefit of the doubt on this one and hope that they will take packaging more seriously in the future.

  19. Danielle says:

    This whole thing is just crazy.

  20. Mark says:

    One of the times I am really thankful that I don’t eat processed foods.

  21. Ashley says:

    Think I’ll be making my own GF nuggets from now on.

  22. Angie says:

    Interesting that these certification programs bring in such large amount of money for these places. No wonder they don’t want to scale back.

    • Gluten Free Mike says:

      Indeed. Certification was one of the largest (if not the largest) revenue stream for the organization.

  23. Jessica says:

    Shame when things like this happen.

  24. Sophia says:

    I never really looked for products that were certified gluten-free. I am more interested in them being made in a dedicated facility.

  25. Gluten Free Mike says:

    Hi Everyone,
    Thanks for taking the time to comment. The replies are coming in fast and furious and I have to approve them manually so please bear with me. I promise that all comments will be posted.

  26. Sally says:

    How companies can think that people will tolerate a lame explanation for something they should have been doing all along is beyond me.

  27. Jennifer says:

    Thanks for taking a stand for Celiacs.

  28. Laura says:

    Who knew that there was such money to be made in certifying something that has no real tangible guidelines? The sequence of events in this situation are rediculous.

  29. Sam says:

    After the NFCA Domino’s thing and now this I am beginning to wonder if these programs are more like the pay the fee get the certification type of deals. After something like this happens, how can you not think this way?

    • Gluten Free Mike says:

      Absolutely agree. Why would GIG sanction one of (if not its largest) revenue stream? That would be biting the hand that feeds them.

  30. Reese says:

    Great post! I agree that these organizations need to take a better look at the services they are providing. If the can’t handle then stop.

  31. Anna says:

    Really nice post. Thanks for taking a stand.

  32. Hillary says:

    Amazing how some of these companies really don’t get it.

  33. Rachel says:

    Makes me rethink what certification really means. From the sound of this not very much — but agree it is better than nothing.

  34. Eve says:

    There are certain expectations I have when buying GF products. Clearly the companies do not share my expectations or concerns.

  35. Lisa says:

    Shame on both GIG and Applegate for allowing this to happen.

  36. Caitlin says:

    I’m just glad that no one one consumed these but things like this should not happen. Both parties dropped the ball on this one.

  37. Gina says:

    Yet another example of why we need federal regulation to protect Celiac consumers.

  38. Jonathan says:

    Interesting that GIG did not really do anything to Applegate for letting this happen. I guess they are not going to go after one of their largest revenue streams. That alone speaks volumes to how the organizations really operate.

  39. Lesley says:

    Really kind of scary to think that something on this scale could happen.

  40. Aaron says:

    GIG clearly demonstrated that there certification program is not all that it promises to be. I really wish that these organizations would stick to advocacy and stop trying to be things they are not (or in this case are not capable of doing effectively).

  41. Kelly says:

    It is scary enough learning a new way of eating as a newly diagnosed Celiac and I really thought that certified gluten-free meant something. Clearly I was wrong. I think I will just stick to companies that do their own testing or manufacture in dedicated facilities. I am just not willing to take a chance anymore.

  42. Sharon says:

    I think that we as consumers have every right to have higher expectations when we pay premium prices for items that are supposed to be held to a higher standard. As someone else commented, it’s like they don’t want to bite the hand that feeds them — in this case GIG.

    • Gluten Free Mike says:

      Well said Sharon. I have long thought that such programs were really just revenue streams and GIG’s response or lack there of speaks volumes.

  43. Lucas says:

    I for one am not going to buy Applegate products anymore. If this happened, who really knows what really goes on behind the scenes and without a dedicated facility I am not going to take that risk.

  44. Jessica says:

    Hopefully people will learn not to rely on a seal on a package and will start supporting companies that have dedicated facilities to manufacture our products.

  45. Gerry says:

    I think that this incident shows many of us were lulled into a false sense of security by relying too heavily on these programs. Perhaps this is the wake-up call we need.

    • Gluten Free Mike says:

      It’s true Gerry, we do sometimes become complacent. I know I am guilty of it sometimes. It’s not easy being on your A-Game 24/7 so having a bit of help to navigate the product landscape was welcome — however it looks like we were being steered without a very good map.

  46. Beth says:

    It is going to take me a while to trust Applegate again. I never really gave GIG much of a thought and after this will put my support elsewhere.

  47. Thomas says:

    It speaks volumes that nowhere on the GIG website does it even reference the recall. At least Applegate has it on their front page. This whole certification is clearly a money-spinner for GIG and they know it. I saw they never got back to you with the number of inspectors they have. Wonder why that is? Likely because it would show that they are flying by the seat of their pants with their certification checks.

  48. Nancy says:

    I just don’t get why these advocacy organizations feel the need to operate in areas that they really have no business in (money aside). They should focus on more grassroots efforts to raise awareness rather than grasping at straws totry and be something they clearly are not capabale of doing efficiently. Nor do I think it is there place to certify something that has no standards. It just does not make sense.

  49. Angela says:

    It is truly disheartening to know that such a thing could happen form something that was suppose to be monitored. Makes you wonder what goes on where there in no monitoring.

  50. Peter says:

    Let’s be real here for a minute. Who do you think is working a food packing line in a plant? A Ph.D, or a minimum wage non english speaking person. I am in no way demeaning these jobs, they are very hard working. I’m simply saying you can’t expect attention to detail at a level like this. Where are the supervisors? Maybe they weren’t even there. I would hate to see what goes on behind the scenes in many of our food plants, many of the restaurant kitchens I’ve eaten at, etc. Horsemeat at burger king? Gluten in nuggets? How much has really changed since The Jungle?

    • Gluten Free Mike says:

      Peter, thanks so much for taking the time to comment. I completely get what you are saying and aggree about the attention to detail (or lack thereof). But that is where I would have hoped that the GIG certification (particularly in a shared line facility) would have had some kind of safeguarding in place to at least make it more difficult for something like this to happen. I was stunned that only after the incident did Applegate put additional processes in place. My question to both Applegate and GIG is where were these prior? I think this whole recall was a good wake-up call for me because I’ll be the first to admit I might have become a bit complacent in the years since my diagnosis — sometimes sacrificing diligence for convenience. Even with strict regulation (for areas outside of GF) mistakes still happen and will no doubt continue to happen, but I just have (well had) higher expectations when something is “certified”.

    • Brendan says:

      But peter, that is why they need procedures and protocols in place that these kinds of mistakes immposible. I get that it is hard, but we also pay more for gluten free products, and if it is going to say certified gluten free on the label, it ought to be gluten free. Celiac disease is a medical condition and we cant keep it under control if companies dont take gluten free labeling seriously.

  51. Brendan says:

    The issue is two-fold: celiac is a disease that requires absolute adherence to a gluten free diet and companies charge more for gluten free products presumably because more testing and certification is required. So it is a slap in the face to pay more and still get gluten. I consumed one of the affected boxes of chicken nuggets. I think since then, this has happened again. The response by both applegate and GIG have been entirely inadequate. If applegate is going to insist on having identical products, with one being gluten free and one being non gluten free, there needs to be an easy way for us to identify the difference visually.

  52. Bren says:

    Certified Gluten Free labels from GIG are increasingly carrying less weight for me. I realize this is an old story, but I’ve had about three or four problems with foods carrying that seal in the past year alone. I don’t know if they’ve changed their practices, gotten lax, or what but definitely feel this organization is doing more harm than good these days. Someone needs to take them to task because we rely on this labeling for our health (and part of me feels like they just rely on it for funding or something).

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