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#1 CLN

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Posted 12 June 2017 - 07:07 PM

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?

 

Thanks

David C


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#2 Charles.C

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Posted 13 June 2017 - 02:32 AM

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?

 

Thanks

David C

 

Hi David,

 

Sorry but I have no idea what the "red" means.

 

Assuming you are involved with Food(??) / a GFSI recognized Standard, the answer based on previous threads here is NO.


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Kind Regards,

 

Charles.C


#3 CLN

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Posted 13 June 2017 - 02:05 PM

Good morning Charles

 

Thanks for the quick reply. Let’s see if I can provide some clarification on the Red type. Perhaps I should have said, "Finished Good, Work Process, and palletized ingredients" with Multi-layer protection that consist of Primary, secondary, and sometimes tertiary packaging liners."

 

I'll take another look at the previous threads that you had mentioned, unless they were updated lately, I don't recall the treads mentioning off-site warehousing, 3PL Distribution, and / or Distribution Centers.

 

Thanks, I really appreciate your guidance and I will get back with you if I have more questions or any disagreements

 

David


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#4 FurFarmandFork

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Posted 13 June 2017 - 10:30 PM

If a risk assessment shows that there is no reason for there ever to be exposed products in your facility (completely sealed), and you have a strict spill/packaging damage procedure that takes allergens into account, then provided everything is labeled you can probably relax on the storage requirements (e.g. no storing allergens above non-allergen items).

 

Provided you can demonstrate compliance with your spill response procedure, and the procedure is considered adequate (e.g. all products affected by spill are destroyed), there may be some wiggle room. I struggle sometimes with strict allergen storage when grocery stores for example are not required to stock according to allergens, and presumably it hasn't posed such a food safety risk at this time to be included in the retail food code. On the other hand GFSI is supposed to be above and beyond......


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#5 Charles.C

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Posted 14 June 2017 - 07:26 AM

Standard (if any) is unknown.

Product(s) is unknown.

 

Merely as one example from several here -

 

http://www.ifsqn.com...oduce-facility/


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Kind Regards,

 

Charles.C


#6 CLN

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Posted 14 June 2017 - 12:11 PM

Thank you all for your guidance, I really appreciate your input.  And now I know what direction I need to address my Allergen Management program to ease the congestion of palletized food products.

 

 I like this Food Safety & Quality forum, it provides many different perspectives on how handle a problem or how to write a procedure and so on.  I have been a long time reader and seen your forum grow, I will recommend this website to my customers to help develop their FS / Quality Plans.

 

Thanks again,

David C


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#7 Ryan M.

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Posted 15 June 2017 - 12:51 AM

Yes, but it requires a strong risk assessment and a strict adherence to spill procedures.


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#8 CLN

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Posted 15 June 2017 - 01:37 PM

Ryan

 

Understood, and well conveyed. I have a meeting set-up with our Food Safety Team to review our updated ACP, to determine whether to except or disapprove changes in our risk analysis. 

 

And It's going to be interesting internal debate within this FS team. Our team is put together involving people with multi skill sets from, Retail, Logistics, Manufacturing, Warehousing and the occasional customer input / visit. We always come out of the meetings with a lot more knowledge than before about the Food Business.

 

 As you had mentioned before about Grocery stores (storage practices), and let’s throw in the LTL carriers exemption into the mix... Are always brought up and debated.

 

The food business is full of contradiction, that’s why we defer to people like you and this forum to clear the weeds.

 

Thanks again for your input.

 

David C


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