Third Party Cold Storage of Cryo-vac Dairy Product

I recently performed an audit for a company I just started working for and struggling with my findings.  

The company I audited is a third party cold storage plant.  The setup is a large bank of docks with gated partitions segregating the leased docks for each company within the massive complex.  

The reason I mention this is that although we would only be storing cryo-vac sealed dairy products in this facility, during an audit I found that there is not only no documented evidence of routine and effective cleaning, there is also no environmental program or allergen control program to validate their procedures (I should mention that storage for this company is not strictly dedicated for dairy-they also store raw pork and other products across multiple industries.  To me this raises huge red flags for cross contamination and overall sanitation at the storage company.

My company is not yet SQF but I am a driving force behind pushing them for certification, something senior management has stated that we WILL do.  On the other hand, I am getting large pushback from senior management essentially saying that my audit of this cold storage facility was almost a formality and that we WILL likely use them for storage.  

Am I erring too much on the side of caution or am I assessing the situation fairly in my observations and required corrective actions (something I should push heavily on senior management).

I welcome all comments and if I need to clarify anything please let me know.

Thanks in Advance!

Did the Company have a HACCP system and could they document why they did not have a prerequisit as cleaning in Place?

Since there is only storing of packed goods there might not be a need for regular cleaning, but I definetly think they should have a plan in place for atleast a yearly clean and a plan for action in case Things break. Same goes for allergenes, a contingency plan might do in case of breakages as long as Things are all covered by Outer packaging (which is considered unclean and shall be removed before entering clean zone in Food manufacturing anyways..).

More importantly; did they have a good pestcontrol program in Place?

Upper management really can not have it both ways - as in, your company is going to get SQF certified at some point and that means literally changing the food safety culture of a company, yet they are content that their supplier of cold storage can be sub-standard in how they store product.

Believe it or not, there are cold storage/logistic facilities that are GFSI certified, or better yet tell the cold storage facility to get certified, to put an SQF or BRC or IFS program into place and adhere to it.

You are going to have to show what your requirements are for the cold storage of your product - your management can't compromise product safety in the supply chain after it leaves their facility but before it gets to outlets that sell to consumers.

You really can't get around using a facility to store your product that doesn't play by the same rules as your company does; this blind eye to out of sight, out of mind attitude from your upper management will come around and bite them in the butt one day - might be on the day that your certification audit is, making it a very bad day indeed.

Thanks for the responses above.  They do have a pest control program in place but no HACCP plans.  For me it is also the lack of documentation that made me feel very uneasy; especially given the fact that I am trying to perpetuate a culture change for SQF in my company as well.  I have developed SQF programs for companies in the past but this is by far the stiffest resistance I have met as of yet.  I think I just have to plant my feet firmly in the ground and document, document, document, document everything I see in audits and around the facilities.  

Hi Guitardr,

IMEX at least 2 routes may occur depending on the situation background -

(1) QA/Top Management have an agreed set of audit decision rules for overall approval of external facilities, eg based on Critical/Serious etc (or scoring). Sort of textbook ideal. This would also be the case if one were pseudo-auditing to a specific FS Standard.

(2) Specific, internally, agreed audit rules for approval do not exist and, for example, Top Management  implement a combined  "Business / QA" approach.  Personally, if this type of situation is operative, I have tended to seek a diplomatic approach such as  -

(a) Use the audit checklist as raw "evidence" and append a short report on Products / Process followed by -

(b) Add a Conclusion stating something like either (i) the above audit results are IMO satisfactory so everybody's happy or (ii) the above results are acceptable with respect to (A,B,C) but also included some serious defects such as (D,E,F) which would IMO need to be corrected in order to achieve an overall satisfactory assessment (or be acceptable to some particular FS Standard).

The above offers a basis for further Top Management dialog from both sides. If your TM simply overrule yr opinions it becomes a Policy issue which IMO is out of yr domain. (Unless you choose to make it otherwise).

The unstated objective is to avoid arrows from both directions. :smile:

Charles,

Thanks for your input, it's funny this is exactly what I did last night; I wrote an exhaustive report based on an audit (which I had to write-unfortunately there was no pre-existing supplier audit available) and based on my observations issued a disposition as "conditional" only if certain criteria (namely the huge gaps I saw) were corrected and maintained.  This report has found it's way to senior management so I'm keeping my fingers crossed!