Henk started Sneeubos Foods in Bronkhorstspruit eleven years ago with one tunnel oven and his mother’s wheat rusk recipe. Today the same oven also bakes a gluten-free oat and seed granola two days a week. When a national retailer offered an own-label listing for the granola, on condition that the site first gained BRCGS Gluten-Free certification, Henk gave the project to Dumisani, his technical manager, and asked Phindile, who runs finance, for an audit budget. Dumisani’s gap review said little about fees. The gluten-free policy carried the signature of a production manager who had retired. Nobody had booked Dumisani on the BRCGS Issue 4 Sites Training course or named anyone to stand in for him. Purchasing bought oats on a specification that said “wheat-free” and nothing more. When the rusks ran late, the granola simply followed them into the oven. The laboratory budget had been trimmed, and sales had put “certified gluten-free granola” on the website. The QA office could fix none of it alone: every gap was a decision taken further up.
In short
- Section 1 of BRCGS Gluten-Free Issue 4 places the gluten-free management system (GFMS) with senior management: the people who can commit money, people and time.
- The gluten-free policy carries the dated signature of a senior manager based at the site, is renewed yearly and on any change of signatory, and reaches every employee (clause 1.1.1).
- Senior management appoints a GFMS team leader with real authority and a written deputy, and the team leader needs a pass in the BRCGS Gluten-Free Issue 4 Sites Training course (clause 1.2.3).
- There is no culture-plan clause. Culture shows in named people to report to, rules enforced on everyone, a senior manager at a team meeting at least once a year and a reporting route upwards (1.1.2, 1.4.2, 1.4.3).
- Decisions on suppliers, oats, shared lines and testing are commercial choices with gluten consequences, and changes need a GFMS review before they happen (clause 2.3.1).
- Claims follow the law of each country of sale (clause 4.3.1), and certification wording belongs to the site, never to a product, on any pack, web page or tender (clause 4.3.3).
Why BRCGS Gluten-Free management responsibilities start with the owner
Issue 4 of the BRCGS Global Standard Gluten-Free rests on five building blocks, and the commitment of senior management comes first. The order is deliberate. Gluten reaches a gluten-free product through purchasing, product development, the production plan, engineering, hygiene, the packing hall and the people who answer customer calls, and only those at the top can make all of them pull the same way. In the Standard’s terms, senior management is whoever runs the organisation at the very top and can delegate authority and release resources: in an owner-managed factory, the owner and directors.
Section 1 of Part II is written for that group, and much of the rest depends on it. A supplier approved in a hurry, a gluten-free run squeezed in after a wheat run or a claim drafted by an agency all trace back to whether management gave the gluten-free management system (GFMS) the authority, time and money it needed. For what is certificated, the food safety certificate underneath, trademarks and audit options, read our guide to BRCGS Gluten-Free certification. This article is about the decisions only owners and directors can take, and the evidence they leave behind. When one of those decisions goes wrong, our guide to gluten-free claim risk sets out what a failed claim costs, from the first 48 hours to the 28-day clock.
| Decision | Clauses | What a director should be able to show |
|---|---|---|
| The gluten-free policy | 1.1.1 | Signed and dated within the year by a senior manager at the site, and known to staff |
| Resources and authority | 1.1.2 | Approved spending, and named people for corrective action and for enforcing the rules |
| The Standard and the audit date | 1.1.3, 1.1.4 | A genuine copy of Issue 4 and the re-audit booked before its due date |
| Team leader, deputy and team | 1.2, 1.3 | Real authority, a written deputy, the Issue 4 Sites Training pass, a mixed team |
| Meetings and reporting | 1.4 | Minutes with owners and dates, and a senior manager present at least once a year |
| Suppliers and oats | 2.3.1, 3.4 | A review before any supplier change, and every supplier approved by a permitted route |
| Shared lines and testing | 3.9.1, 4.4.1, 4.7 | A controlled schedule, a validated clean and a risk-based sampling plan |
| Labels, claims and marks | 4.1.1, 4.2, 4.3, 6 | One sign-off route, and no product described as certified |
The policy, the budget and the audit date you sign for
The gluten-free policy can fit on half a page (clause 1.1.1). In substance it commits the top team to a GFMS that is built, run, kept up and improved, and the site to gluten-free products that meet every requirement of the Standard. What auditors test is the signature. It belongs to a senior manager based at the site with authority over section 1, it is dated, it is redone every year and whenever a new person takes that seat, and the whole workforce hears about it. Auditors typically check the name against the organisation chart and ask a packer what it means for her. Henk rewrote it with Dumisani, signed it and took it to every shift for a week.
Clause 1.1.2 is where commitment costs money, so read it as decisions that leave a paper trail. Capital for dust extraction or a separate mixing room. A maintenance budget that keeps equipment hygienic. Real hours for gluten work in the team leader’s week, and team meetings that survive a busy order book. Names on the organisation chart for who may launch a corrective action, and for who may stop anyone, a visiting director included, who ignores the rules. Commitment that never reaches a budget or a job description is hard for an auditor to find.
Two short clauses catch owners out. The site needs an authentic copy of the current issue, bought rather than copied, and a routine for tracking the binding position statements BRCGS publishes (clause 1.1.3). And once certificated, the site itself must make sure each recertification audit happens on or before its due date (clause 1.1.4). A late audit without a reason the protocol accepts opens the next one with a major non-conformity; staff shortages, building work and lining up two audits do not count.
Appointing the GFMS team leader, the deputy and the team
Senior management appoints the GFMS team leader, and the appointment must carry authority, not just a title (clause 1.2.1). The team leader answers for the system from design and validation through daily running and improvement, is the first contact for auditors, and needs in-depth knowledge of your system that stands up to questioning (clause 1.2.2). Test the authority: if the team leader says a gluten-free run cannot start because the clean has not been signed off, does production wait? If the answer changes with the shift manager, the authority is decorative. Put it in writing and support the team leader openly the first time it is tested.
Clause 1.2.3 names one course: the team leader needs a pass in BRCGS’s own Global Standard Gluten-Free Issue 4 Sites Training course. An Issue 3 certificate does not match that wording and no transition period is stated, so budget for it when you appoint. Nothing else satisfies the clause, ASC’s courses included; our BRCGS Gluten-Free Issue 4 for Management course is written for the directors and managers around the team leader, not as a substitute. A successor needs the same pass.
Write the deputy down unambiguously. Either the team leader or the deputy has to sit in on the opening and closing meetings of every audit, the audit goes ahead even if the leader is away, and the protocol also looks for the site’s top operations manager, or a stand-in, at both. Around the leader sits a team drawn from quality, procurement, development, hygiene, production, engineering and any other function whose decisions touch gluten (clause 1.3.1), each knowing gluten controls and enough about products, claims, law and hazards to spot a risk in their own area (clause 1.3.2). Outside experts may plug a knowledge gap, but running the system day to day stays with the site (clause 1.3.3), so spell out the split of duties in any consultant’s contract.
Dumisani was booked on the Sites Training course the week Henk read the gap review, and the granola section’s longest-serving supervisor became his written deputy, chairing every second team meeting so the role is real.
Culture and reporting routes: how bad news reaches the boardroom
Gluten-Free Issue 4 has no separate clause asking for a culture plan or a confidential reporting system for staff. Separate BRCGS guidance on product safety culture is available, on Participate, if you want a framework. Within this Standard, culture is judged through ordinary evidence: whether people on every shift know whom to tell, whether those named to enforce the rules are backed, and whether issues travel upwards fast enough to act on.
Clause 1.1.2 asks management to tell staff why the GFMS and the law matter and to whom problems are reported, and to give named people the power to hold everyone on site to the rules: contractors, visitors and directors included. The first time a hygiene supervisor turns a senior visitor back at the gluten-free room, management’s response tells every employee whether the rule is real. To go further than the Standard asks, our Food Safety and Quality Culture course for management and supervisors covers building and measuring culture.
The GFMS team meets at planned intervals, at least once a year, and sooner for a new product, a serious incident, an emerging risk or a change of supplier, recipe, process, equipment or cleaning (clause 1.4.1). Minutes are kept, actions close on time and decisions reach those who must act, senior management included. At least one senior manager attends at least one meeting a year (clause 1.4.2). Treat that as the floor: a director who hears about a failed swab six months late cannot fund the fix in time.
Between meetings, there must be a way for GFMS issues to reach senior management (clause 1.4.3): a monthly one-page report, or a rule that any out-of-specification gluten result reaches a director the same day. Build it in both directions, because dropping a product, changing a supplier on price or taking on a customer changes what the GFMS must control. At Sneeubos the oats specification had been agreed without Dumisani ever seeing it. Phindile’s fix was blunt: a purchase order for a gluten-free material from a new supplier, or on a new specification, is released only with the team leader’s initials beside the buyer’s.
Suppliers and oats: the buying decisions behind the claim
Purchasing decisions are commercial, but each one has a gluten consequence. A documented risk assessment of every ingredient and input, processing aids and packaging included, hunts for hidden gluten as well as the obvious, and drives acceptance checks, testing and supplier approval (clause 3.4.2). It is updated when a supplier or its process changes, a new risk emerges or a recall involves one of your materials (clause 3.4.3), and the GFMS is reviewed before a change of gluten-free material or supplier, not after (clause 2.3.1).
All suppliers of gluten-free materials, stand-in suppliers too, go through a written approval procedure scaled to risk, using at least one of three routes: a Gluten-Free certificate covering the item, a supplier audit that included gluten control, or a set of four documents (clause 3.4.4). Our article on gluten cross-contact explains how each works at goods-in. The director’s question is different: who may approve a supplier when the regular one cannot deliver?
The Standard’s root cause appendix answers with an example worth reading. A site took in a material although the supplier’s approval audit had not happened. Pointing at a travel embargo was rejected as a root cause, since the embargo did not explain the decision to use the material; the cause accepted was the lack of any written stand-in approval procedure. The fix named, among other things, who may authorise a raw material in an emergency. That decision is yours, and it is easier made calmly in advance than at 18:00 on the day a supplier fails.
Oats deserve their own board conversation. In the Standard’s glossary, oats count as a gluten source unless you can verify they are gluten-free, which puts the proof on you: approval, specifications and test results. Apart from that footnote and the AOECS labelling rule for Crossed Grain packs that contain oats, Issue 4 has no oat-specific controls. Questions about how the crop was grown, harvested, moved and cleaned are good practice that BRCGS does not require, yet without the answers “verifiable” is hard to prove. Claim rules are set market by market, so check how each one treats oats (clause 4.3.1). A “wheat-free” specification answers none of these questions.
| Buying decision | Question to settle first | Clauses |
|---|---|---|
| A cheaper supplier of a gluten-free material | GFMS reviewed and risk assessment updated before the first order? | 2.3.1, 3.4.3 |
| An emergency supplier in a shortage | Who may authorise it, by which route, with what records? | 3.4.4 |
| Oats | Provably verifiable gluten-free oats, and accepted in each market? | Glossary, 4.3.1 |
| A certificate of analysis instead of a test | Specific to the consignment, from an accredited laboratory or a validated, proficiency-tested method? | 3.4.6 |
| An outsourced processing step | Gluten-Free certificate, or an audit within the last 12 months? | 3.5 |
Shared lines and scheduling: a capital decision with a gluten price
Sharing equipment between wheat and gluten-free products is one of an owner’s biggest calls, and the Standard does not insist on a dedicated line. It asks for controls against substitution and cross-contact that suit your site (clause 4.4.1): the production plan, how people and flour move, who owns which scoop, coat and spanner, airflow, rework and cleaning between runs. Whatever you choose must be validated. Where cleaning or another prerequisite programme controls gluten, the site says so and proves it works, with technical support and data showing monitoring would catch a failure before product leaves the site (clause 3.9.1).
| Layout choice | The cost | The proof an auditor will want |
|---|---|---|
| A dedicated gluten-free room and line | Capital, floor space, lower utilisation | That people, materials, tools and air stay segregated (4.4.1) |
| A shared line, gluten-free first after a validated clean | Cleaning time and a fixed slot in the plan | A clean validated on the worst case, and monitoring that catches a failure before dispatch (3.9.1) |
| A shared line, gluten-free wherever it fits | Little at first, a great deal later | Almost nothing; every move of the run changes a gluten control (2.3.1) |
Henk’s decision at Sneeubos cost one production slot a week. The granola now runs first on Thursday after a validated wet clean, the production manager cannot move it without Dumisani’s agreement, and when the clean is not signed off, the run waits. A schedule change on a shared line is a change to a gluten control, and clause 2.3.1 expects a GFMS review before it, not after the first complaint.
The packing hall works the same way. Section 5 of Issue 4 expects packaging to be issued and returned under control, lines cleared and signed off between products, labels checked during the run and scanners challenged. Someone trained has to do that on every shift, agency staff included, which makes it a staffing decision.
Testing budgets: paying for evidence, not reassurance
Laboratory spending is easy to cut because nothing seems to happen when you cut it. In a gluten-free business it is the evidence that every other control works. The sampling plan comes second: first the site scores the gluten risk of each material it buys and each step it runs, using the method in the BRCGS Guideline on Sampling and Testing for Gluten, and only then decides sample numbers, accept and reject criteria and the statistical confidence it needs (clause 4.7.1). Once a year or more, an outside laboratory with ISO 17025 accreditation must check your in-house testing, and its accreditation has to list gluten, with the method validated in that laboratory for your type of product (clause 4.7.2). Accreditation for gluten in flour says nothing about gluten in granola, so read the matrix on the laboratory’s schedule, not just the price.
The number results are judged against must come from the right source. The Standard sets no single gluten limit for sections 1 to 7: a finished product must comply with the law of the country where it is sold (clause 4.3.1), and a customer’s specification may be tighter. Only products carrying the AOECS Crossed Grain Trademark have a figure in the Standard: no more than 20 mg/kg, the same as 20 ppm, in the food as sold, tested by the R5 sandwich ELISA (Mendez method) or, for fermented or partially hydrolysed gluten, the competitive R5 ELISA (clauses 8.1.1, 8.6.1). Write each product’s limit and its source into the specification.
Phindile restored the laboratory budget after Dumisani walked her through the plan line by line: intake tests on oats, the first granola after each changeover, finished product across both shifts and the annual verification, and what each one proves. Have that conversation before a budget round, not after a high result.
Labels, claims and marketing: the sign-off that carries the risk
The claim on a pack is where every other decision meets the shopper, yet its pieces are often signed off separately: recipe, wording, artwork and the retailer’s proof. The Standard pulls those threads together. The GFMS team leader agrees every new or changed formulation (clause 4.1.1). Labels are approved, approved again after any recipe change and compared with the approved proof when they arrive (clause 4.2.1); a customer that controls its own artwork gets the facts it needs and early warning of anything that changes them (clause 4.2.2); and superseded labels and film are quarantined and destroyed (clause 4.6.1).
Three rules govern the wording. The gluten content must meet the law of each country of sale (clause 4.3.1), South Africa included, so an export order may bring a different rule. The three marks BRCGS manages, Informed Gluten-Free, Beyond Celiac and Celiac Canada, appear on a pack only once a Trademark Approval Form has been signed and BRCGS has approved the use (clause 4.3.2); Issue 4 aims Informed Gluten-Free at regions such as Africa, which makes it the probable choice here, but confirm with BRCGS before artwork is drawn. And where those marks are used, no pack, advert or web page may talk about certifying the product; the site and its GFMS are what is certificated (clause 4.3.3). The BRCGS Gluten-Free logo is for letterheads and marketing material only; it never appears on products or packs.
Trademarks also bring a register. The site keeps a Schedule A, signed and dated by BRCGS, for each brand owner using BRCGS-managed or ACELMEX marks, and BRCGS hears immediately when a trademarked product is added or dropped, a barcode changes or production for a brand owner stops (clauses 6.1.1, 6.2.1, 6.3.1). One of the Standard’s worked examples is a major raised because a Schedule A had fallen out of step with the marks actually printed, partly because senior management had discontinued trademarked products and nobody told the quality team. Make the update part of the sales decision itself.
| Decision | Who signs | What they confirm |
|---|---|---|
| New or changed recipe | GFMS team leader | Gluten risk of every ingredient, approved suppliers, line and schedule (4.1.1) |
| New or changed label or film | Technical, with the team leader | Composition and wording against the specification (4.2.1) |
| A claim for a new market | Technical or regulatory lead | That country’s rules, recorded on the specification (4.3.1) |
| A BRCGS-managed mark on a pack | Commercial director | Signed Trademark Approval Form and Schedule A (4.3.2, 6) |
| Website, brochure or tender text | Marketing, checked by technical | No product called certified; no logo on packs (4.3.3) |
| A delisting or barcode change | Whoever approves the sale | BRCGS told and the Schedule A corrected (6.2.1) |
Sneeubos took the website line down the day Dumisani raised it, and nothing carrying “gluten-free”, “certified” or a trademark now goes to print or online without his initials. Our Allergen Labelling and Artwork Control course covers a full artwork approval workflow.
Five things to do this week
- Pull out the gluten-free policy and read the signature and date. If the signatory has moved on or the date is over a year old, revise it, re-sign it and take it to every shift.
- Ask for your GFMS team leader’s Issue 4 Sites Training pass certificate, or the booking confirmation, and the letter naming the deputy.
- Ask purchasing for every change of gluten-free material or supplier in the last 12 months, emergency suppliers included, and check each had a GFMS review and an approval route before first use.
- Look at the next four weeks of the production plan for every shared line and ask who can move a gluten-free run, and on whose say-so.
- Search your website, brochures, tenders and packs for the word “certified” beside a product name, and check no pack or carton carries the BRCGS logo.
Related course: BRCGS Gluten-Free Issue 4 for Management
Four self-paced hours for the owners, directors and senior managers of gluten-free sites. The five modules run from what the Standard expects of management, through commitment and the GFMS team, suppliers, oats and claims, and operations, testing and recall, to certification and audit findings. Every module ends with a case study, a knowledge check and a scenario game, and a final assessment leads to an ASC course certificate. It does not meet clause 1.2.3, which requires the GFMS team leader to pass BRCGS’s own Issue 4 Sites Training course.
See the BRCGS Gluten-Free Issue 4 for Management course (4 hours, online, R1,195). Training a team? Choose “EFT or company invoice” at checkout, or WhatsApp us for a quote.
Common questions
What are senior management’s responsibilities under BRCGS Gluten-Free Issue 4?
Section 1 expects senior management to sign, date and renew a gluten-free policy known to all staff, provide resources, name people to act on problems and enforce the rules, appoint a GFMS team leader and deputy, attend at least one team meeting a year, keep a reporting route, hold a genuine copy of the Standard and recertify on time.
Does the GFMS team leader need a specific course?
Yes. Clause 1.2.3 requires the team leader to have passed the BRCGS Global Standard Gluten-Free Issue 4 Sites Training course. Courses from other providers, including ASC’s, cannot meet that clause, although they help the wider team understand the Standard.
Does BRCGS Gluten-Free Issue 4 require a culture plan or confidential reporting?
There is no separate clause for either. The Standard expects staff to know whom to report problems to, named people who can enforce the rules, at least one senior manager at a GFMS team meeting each year and a route that brings issues to senior management. BRCGS publishes separate guidance on product safety culture.
Do we need a dedicated gluten-free production line?
Not necessarily. Clause 4.4.1 asks for controls suited to the site, including scheduling and cleaning on shared equipment, and clause 3.9.1 requires them to be validated, with data showing monitoring would catch a failure before product leaves the site. Changes to the schedule, process or cleaning need a GFMS review first.
Who should sign off gluten-free claims and marketing?
The GFMS team leader agrees new or changed recipes, labels are approved and re-approved when recipes change, and claims are checked against the law of each country of sale. BRCGS-managed trademarks need a signed Trademark Approval Form first, no wording may present a product as certified, and packs never carry the BRCGS logo.
Next step. To give your board one shared picture of these decisions before you book an audit, the BRCGS Gluten-Free Issue 4 for Management course works through the Standard as a series of management decisions, with South African case studies. Supervisors, buyers and production teams can start with the Introduction to BRCGS Gluten-Free Issue 4 course, and for the wider BRCGS family see our BRCGS certification and training hub for South Africa.
This article is general guidance written for South African food manufacturers. It is not a substitute for the Standard: a site is audited against the BRCGS Global Standard Gluten-Free (Issue 4) together with any position statements in force, and the Standard requires the site to hold a genuine current copy. Check brcgs.com for the current issue and position statements, and confirm the gluten-free claim rules of every market you sell into, South Africa included. Clause numbers are given so you can navigate your own copy. ASC Food Safety Training is independent of BRCGS: this article and our courses explain the Standard in our own words, are not endorsed by BRCGS, and lead to an ASC course certificate, not a BRCGS qualification.