I am in the process of reviewing and rewriting our Allergen Storage Practices and need some guidance.
We are a 3PL (Third Party warehousing) which means the materials are owned by the customer that are pre- packaged, and contained in packaging that doesn’t require any rework from our inhouse staff. In other words, how the product comes into storage is how it is shipped out. The food product is best described as multilayer packaging protection from foreign material as Primary, Secondary, and Tertiary levels, and meets the FALCPA requirement.
Due to compacity issues in the storage racking system, we are finding storing allergens like to like very difficult to manage and laborious to apply best practices. Also, we have control measures in place to handle product damage, product spills, and Allergen labeling nonconformities.
Now my question is: Could I write an Allergen Storage Procedure based on a low risk assessment of cross contamination, and store them anywhere in the racking as long I have control measures in place to mitigate the chemical hazard?