Gluten-Free Compliance Checklist for Philadelphia Food Service

Philadelphia Health Department Gluten-Free Standards & Labeling Requirements

The Philadelphia Department of Public Health follows FDA guidelines for gluten-free labeling (21 CFR 101.91), requiring products labeled "gluten-free" contain less than 20 parts per million (ppm) of gluten. All menu items, packaging, and staff-facing documents must accurately reflect whether items are gluten-free or may contain gluten. Philadelphia inspectors verify that allergen statements match product certification documentation and that staff can identify which ingredients are certified gluten-free. Ensure all supplier certificates of analysis and product documentation are on file and current. Any claims of "gluten-free" must be substantiated—verbal claims alone do not satisfy compliance.

Cross-Contact Prevention & Dedicated Equipment Inspection Items

Philadelphia health inspectors specifically evaluate physical separation during gluten-free food prep to prevent cross-contact. This includes dedicated cutting boards, utensils, preparation surfaces, and separate storage areas for gluten-free ingredients away from wheat-containing products. Flour-based products and bread should be stored in sealed containers on separate shelves, ideally above gluten-free items. Fryers must not be shared between gluten-free and regular fried foods unless deep cleaned between batches and documented. Staff must be trained on handwashing protocols between handling gluten-containing and gluten-free items. During inspections, officials observe prep station setup, storage organization, and handwashing practices to confirm no cross-contact risk.

Common Philadelphia Violations & Documentation Requirements

Frequent gluten-free violations in Philadelphia include unlabeled items without allergen disclosure, commingled storage of gluten and gluten-free products, and inadequate staff knowledge of which menu items are gluten-free. Inspectors also cite inadequate cleaning procedures for shared equipment and missing supplier certification documents. Maintain written procedures documenting gluten-free preparation protocols, staff training records, and supplier verification. Keep a log of gluten-free menu items, daily cleaning schedules for dedicated equipment, and incident reports if cross-contact occurs. The Philadelphia Department of Public Health may issue violations under the Health Code if documentation is incomplete or staff cannot clearly explain gluten-free protocols during unannounced inspections.

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