Houston Gluten-Free Compliance Checklist for Food Service

Federal & Local Gluten-Free Labeling Requirements

The FDA defines "gluten-free" products as containing less than 20 parts per million (ppm) of gluten. Houston establishments cannot label menu items "gluten-free" unless they meet this standard and can document it via supplier certifications or testing records. Texas HHSC Rule 165.1.1 requires food service operators to maintain written evidence of compliance. During inspections, the Houston Health Department will request supplier documentation, ingredient statements, and formulation records for any item marketed as gluten-free. Keep all certifications from ingredient and product suppliers on file for at least two years.

Cross-Contact Prevention & Kitchen Procedures

Cross-contact—transfer of gluten through shared equipment, surfaces, or utensils—is the leading cause of gluten-free violations in Houston inspections. Establish separate prep areas, cutting boards, colanders, and toaster ovens exclusively for gluten-free items; label these visibly. Train all kitchen staff on the difference between cross-contamination and cross-contact, and document training with sign-in sheets. Use separate fryers, if frying gluten-free items, or fry gluten-free products first using fresh oil. Inspect and clean equipment thoroughly before gluten-free food preparation. Employees handling gluten-free orders should change gloves and wash hands before beginning prep to prevent transfer from flour dust or previous food contact.

Common Violations & Inspection Checkpoints

The Houston Health Department frequently cites establishments for mislabeled gluten-free items without documented support, inadequate staff training on gluten-free protocols, and shared utensils or prep surfaces. Missing or illegible supplier certifications is a critical violation—ensure all ingredient labels clearly identify gluten-free status. Staff must be able to explain which items are gluten-free and how they prevent cross-contact; inspectors will interview kitchen personnel. Maintain a simple written procedure document posted in the kitchen stating your gluten-free protocol. Document any customer complaints related to gluten or celiac reactions, and preserve records of corrective actions taken within 24 hours to demonstrate good-faith compliance efforts.

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