CFIA may address yr“co-mingling question somewhere but unfortunately I cannot find any mention.
However I have located some support for a “combined” procedure from the well-known FARRP (see below). Whether a FARRP recommendation would be an acceptable validation for yr auditor I cannot say.
(1-3) are Canadian quotes, (4) is ex-FARRP
incoming materials and packaging materials are handled and stored in a manner that prevents damage and/or contamination (including cross-contamination with allergens).
Incoming materials containing allergens are clearly identified (using a color code or other identification system).
Storage and Handling: Store and handle allergenic foods and ingredients in a manner that will avoid cross-contamination with other food products. This may require dedicated storage areas for the various allergen-containing ingredients handled in the plant. If it is not possible to store allergenic foods and ingredients in separate areas, it is suggested they be stored below non-allergenic foods and ingredients, e.g., in bottom shelf/rack, to prevent allergens falling on other foods and ingredients. Ensure that allergenic foods and ingredients are clearly identified by signs or colour codes.
Incoming Ingredients: Obtain accurate ingredient information from all suppliers to identify all allergens, including allergens present as components (ingredients of ingredients). This can be done by obtaining ingredient specification sheets, letter of guarantees, certificate of analysis or a complete list of ingredients. Ensure that they meet your company's specifications and are completely labelled. You may also consider adjusting formulations to avoid allergenic ingredients.
Store allergenic food ingredients separately from other ingredients – at least 1.5 metres should be maintained between allergens and other ingredients if it’s not possible to store them separately.
Store allergenic ingredients on the bottom of racks to avoid accidental spills on items below them.
Identify ingredients with an “allergen” and/or a colour-coded tag.
food allergens as chemical hazards.pdf 381.48KB
Store allergenic ingredients or products separately to prevent cross-contact. Protocols may include:
- Using clean and closed containers
- Designating separate storage areas for allergenic and non-allergenic ingredients and/or products. When segregated storage is not possible, use other methods such as not storing allergens over non-allergens, storing like allergens (milk and whey) together, etc.
- Using and documenting clean up procedures for spills or damaged containers of allergens
- Using dedicated pallets and bins
- Using clearly designated staging areas for allergenic foods and ingredients
FARRP - Allergen Control Plan.pdf 210.07KB
(see Pg 5/15)
Hopefully of some help.