Auditing Allergen Management as a Distributor Only

Hey there -

I have recently become certified to be our company's internal auditor for our SQF Level 2 program.  Our company is a distributor of packaged (finished) products only and do not deal with any raw materials.  This has caused some hiccups when writing our policies and procedures as we often feel the need to shoehorn the SQF requirements clearly geared towards manufacturers and packers into our daily workflow.

Now that I am auditing, I see that our allergen management program seems to be a bit light.  As we have such a low risk of cross contamination (perhaps a case breaking during handling), I am not sure how to audit this section.  Any ideas from anyone who has dealt with a similar situation?  I think having a risk assessment in place proving our products are packaged and labeled by the manufacturer's seems sufficient to me, but will it stand up to an audit?  We also provide training to our staff who handle cases on the "Big 8" allergens should a product break and need sanitation, but other than that not much is done. 

I appreciate any help!

A very large portion of our business is straight distribution as well.  We are BRC certified, and have been FSSC 22000 certified and they were satisfied with our program.  

We have all the allergens (and combinations) listed in the warehouse receiving/shipping area.  Everyone gets allergen training.  We have dedicated racking for different allergens as well as dedicated floorspace for floor (on pallets obviously) stacked items. 

All pallets are covered with plastic when they enter the facility if they don't come that way from the vendor to limit dust sifting down onto the product during storage.  

There are pallet tags affixed to each pallet that clearly indicates the allergen/allergen combination of each item and the whole darn thing is color coded.  

We put stickers on the pallet tags and corresponding color spots on the racking/floor.  Put the blue dot with the other blue dot.  

JPO,

I'm curious if there is any requirement under your applicable standards to inspect and document for allergen spills within a case that becomes evident on the outside of the case or soils other cases?

Is there any requirement to have a policy and program with procedures for cleaning up after allergen spills from damaged cases or pallets?

Regards

Hey bmmowers. As a distributor, it would be worth requesting a copy of all of your supplier's allergen risk control documents as a start. Then you can see their risks. From that starting point, look at your own - are you breaking pallets down? Are your van drivers mixing boxes in their vehicles? Is the final user placing raw products on the shelf close to each other? 

Just to give you an example - a supplier has a "gluten free" product. This arrives packed and boxed in 10Kg boxes. You keep their product segregated in one area. Then a delivery driver gets an order for 5Kg of this product and and 5Kg of a bread product. Ever the environmentalist, keen on saving cardboard, the driver pops both into one box and drops them into the store. The guy in the store then pops both products into adjacent baskets in the deli, with a shared tongs. Your job as risk assessor is to look at all of these risks, categorise them, and train your staff to appreciate these risks. Hope this helps, but if you want more feedback, just let us know. 

And yes, XY, spillage procedures have to be in place also. Rather sadly, auditors often focus on the obvious rather than the real, intrinsic risks!