Controls required for a customer stored product?

We are a bakery that only produces several variations of one product.  The only allergen in the facility is wheat, and it is universal to all products so no controls are needed.  We recently began a practice of receiving and storing (frozen) another baked product produced by another company.  This was per a customer request as it is then shipped with our products.  This product contains soy and egg.  My question: Do we have to have policies in place for this as we are only storing and shipping it?  Should it be segregated in the freezer?   It is finished product already packaged for retail.  When I voiced my concerns, I was told by upper management that this is none of my concern.  We are BRC certified, and I need to know if this will effect our audit in any way.   

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."

All materials that contain allergenic substances must be listed on a single reference document.

Now that you have allergens other than wheat in your facility, you have to risk assess cross-contamination. Since it's packaged finished product, I'd assume the risk for cross contamination would be negligible. 

5.3.4 says that procedures have to be in place to ensure effective management of allergenic materials to prevent cross contamination. One example would be "physical or time segregation while allergen-containing materials are being stored,  processed or packed."

Based on your risk assessment, you may find that no segregation is necessary. However, If you have the space for segregated storage in the freezer, I would think that's best practice.. Ideally, allergenic products should be totally segregated from non or unlike allergenic products.

Marshall

Hi Miss tammy,

I would suggest you donate a copy of the BRC standard, suitably tabbed and highlighted,  to "Upper Management" within a memo headed Product Risk Assessment. "Risk" is a beautifully suggestive  term IMEX.

Thank you for your input.  I was thinking the same.  I am very tempted to do as I am told and "not concern myself" with the issue.  Just let the "chips fall where they may".  But then I will be the one writing the root cause and corrective action for the NC, so I may as well whip something up to cover our ---!  :hypocrite:

Upper Management should realize that introducing allergens into the plant is a no-no. And it should have been run through the HACCP Team anyway (per BRC Standard).

Just risk assess it, segregate it if you can, write a policy/procedure that addresses storage of the allergen containing finished product, adhere to that policy/program and you should be good to go.

Marshall

Hi Tammy, 

I would respectfully advise you to pick your battles with management on this one. Yes, new allergens are being introduced onto your site, but it's not as if soya and milk are being dumped into your production area from nowhere!

A fully wrapped, enclosed finished product is being delivered to your site. Judging by your description and allergens mentioned, I'm going to guess that it's a chocolate muffin to a bread factory. It is fully wrapped, requiring no further processing. Think of the allergen cross contamination post dispatch from your facility. Will the separate boxes suddenly cross contaminate each other during transport, warehousing and distribution? Is there a larger risk that cross contamination will occur at store / end user level? Personally, I think there is.

Saying that, don't let this pass you be. Mention in your allergen risk assessment that there is a low risk at storage level of allergen cross contamination, but explain that the product is fully sealed, and poses no real threat to your process. Is the final customer sending one truck for a product containing only gluten containing products and another for soya and milk containing products? Didn't think so. 

Best course of action in my opinion is to request a copy of the other supplier's allergen risk assessment. It will look good on file, and may give you some info on how to construct your version when management decide to launch a sesame seeded product. Now THAT is the day when you need to bust some management chops!

Hi SQ,

I suggest a simpler decision procedure –

There are 2 stored products in proximity to each other and each  possesses different allergens.

Is the risk of allergenic cross-contamination increased or decreased by implementing segregation ?

Eureka ! We have a Policy !

Mention in your RA  cross contamination if the packs are damaged in storage or transport i.e. Fork lift truck puncture. Document and train out (with evidence) an incident report form and clean up procedure similar to any FB/Glass incident. including quarantine and sign off decision for the disposition of stock. i.e. scrap, repack ,ok to go.

Regards

Sharon