Hi Barbara,
So it would be interesting to know what controls there are in this area that have enabled you to achieve certification and how many are going to be compromised.
A few areas of the BRC Global Standard for Food Safety Standard come to mind that may assist your argument:
4.3 LAYOUT, PRODUCT FLOW AND SEGREGATION
FUNDAMENTAL: The factory layout, flow of processes and movement of personnel shall be sufficient to prevent the risk of product contamination and to comply with relevant legislation.
4.3.4 The movement of personnel, raw materials, packaging, rework and/or waste shall not compromise the safety of products. The process flow, together with the use of demonstrably effective procedures, shall be in place to minimise the risk of the contamination of raw materials, intermediate/semi-processed products, packaging and finished products.
4.9.1 CHEMICAL CONTROL
4.9.1.1 Processes shall be in place to manage the use, storage and handling of non-food chemicals to prevent chemical contamination. These shall include as a minimum:
• availability of material safety data sheets and specifications
• the labelling and/or identification of containers of chemicals at all times
• a designated storage area with restricted access to authorised personnel
4.9.5 WOOD
4.9.5.1 Wood should not be used in open product areas except where this is a process requirement (e.g. maturation of products in wood). Where the use of wood cannot be avoided, the condition of wood shall be continually monitored to ensure it is in good condition and free from damage or splinters which could contaminate products.
4.15 STORAGE FACILITIES
All facilities used for the storage of raw materials, packaging, in-process products and finished products shall be suitable for its purpose.
4.15.1 Documented procedures to maintain product safety and quality during storage shall be developed on the basis of risk assessment, understood by relevant staff and implemented accordingly.
4.16 TRANSPORT
4.16.5 The company shall have documented procedures for the transport of products, which shall include:
• any restrictions on the use of mixed loads
5.3 Management of allergens
5.3.2 The company shall identify and list allergen-containing materials handled on site. This shall include raw materials, processing aids, intermediate and finished products, and any new product development ingredients or products.
There are probably quite a few more.......
Regards,
Tony