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The focus has shifted toward closing gaps that happen in real retail environmentsbusy counters, high turnover staff, and inconsistent training

(3) When a scientifically valid method pursuant to paragraph (c)(1) of this section is not available because the food contains one or more ingredients that are fermented or hydrolyzed, the manufacturer of such foods bearing the claim must make and keep records demonstrating adequate assurance that the fermented or hydrolyzed ingredients are gluten-free as described in paragraph (c)(2) of this section

Dani Kachorsky , an AP Research and English teacher at Brophy

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