Gluten-Free Compliance Checklist for Orlando Food Service Operators

FDA Labeling & Allergen Declaration Requirements

The FDA defines "gluten-free" as products containing less than 20 parts per million (ppm) of gluten. All menu items claimed as gluten-free must have accurate ingredient statements and supplier documentation proving compliance—inspectors will request these records. Your facility must clearly label gluten-free items on menus, point-of-sale systems, and kitchen prep stations with visible signage. Avoid vague claims like "may contain gluten"; instead, use definitive language supported by testing or supplier letters of guarantee. Train staff to understand the difference between gluten-free and "accidentally gluten-free" items, as the FDA holds you accountable for explicit claims.

Cross-Contact Prevention & Prep Protocols

Orange County Health Department inspectors specifically look for dedicated equipment, utensils, and prep surfaces to prevent gluten contamination. Establish separate cutting boards, toasters, fryers, and utensil storage for gluten-free items—color-coded systems reduce human error. Document your supplier management process: request Certificates of Analysis (CoA) from distributors confirming gluten-free status for bulk ingredients. Implement a handwashing checklist between tasks and monitor flour storage separately from other dry goods. Staff handling gluten-free orders must change gloves and clean work surfaces before starting prep; this is frequently cited in violations when not followed consistently.

Common Violations & Local Inspection Items

The most cited gluten-free violations in Orange County include unlabeled or mislabeled items, lack of supplier documentation, and cross-contact from shared equipment. Inspectors verify that staff can articulate which menu items are truly gluten-free and the reasoning behind that claim. Maintain a written Gluten-Free Program Plan detailing your training, supplier vetting, and prep procedures—this demonstrates due diligence if a violation occurs. Track employee certifications in allergen management; many facilities fail when staff cannot explain their gluten-free protocols. Common documentation gaps include missing supplier letters, expired CoA files, or no record of staff allergen training within the past 12 months.

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