4 replies to this topic

[JRayner1]

Hi

 

Looking at Allergen Management for warehousing.

 

If allergens are sealed and packed, stored at ground level, and a spillage procedure was in place would this satisfy the requirements of BRC storage and distribution. Or is complete dedicated allergen segregation the preferred route to minimize the cross contamination risks in the event of a spillage.

 

 

[Tony-C]

Hi JRayner1

 

Personally I would prefer segregation but your controls will more than likely be deemed sufficient. They should be supported by a hazard and risk analysis.

Relevant parts of the standard:

2 HAZARD AND RISK ANALYSIS
2.7 The company shall identify and record all potential hazards associated with each step of the product flow as identified in clause 2.6. The company shall include consideration of the following types of hazard:
• allergenic materials (e.g. cross-contamination of loose product or outer packaging by allergenic products).

7.4 PHYSICAL AND CHEMICAL PRODUCT CONTAMINATION RISK
Appropriate facilities and procedures shall be in place to control the risk of physical or chemical contamination of product including allergens.
7.4.3 Where allergenic materials are stored or transported, the potential risk of cross-contamination shall be assessed and any necessary additional spillage controls incorporated. Where allergenic materials are packaged in a format at particular risk of damage (e.g. paper sacks) designated storage areas shall be used to reduce risk of damage and cross-contamination of other products.

 

Kind regards,

 

Tony

[jdpaul]

Tony-c my question is regarding this clause also; 21 CFR Subpart O, "Sanitary Transportation of Human and Animal Food"

 

 

21 CFR Subpart O 1.908

(ii) Taking effective measures such as segregation, isolation, or other protective measures, such as hand washing, to protect food transported in bulk vehicles or food not completely enclosed by a container from contamination and cross-contact during transportation operations.

 

'

 

Beverages are completely enclosed by their container so these industries are exempt from Subpart O, however there is the clause above. My issue is that FDA inspectors (dairy, etc) will insist that we still need allergen identification and denoted as spill-preventive on route to markets (e.g., hy-vee, walmart, etc).

Edited by jdpaul, 18 March 2019 - 11:19 PM.

[Tony-C]

Hi jdpaul,

 

Are you saying that this transport to retail is out of your control?

 

Kind regards,

 

Tony

[zanorias]

Hi JRayner1,

 

My previous site was a warehouse with BRC S&D, we didn't segregate all allergens only though with a higher risk of damage i.e. bulk bags of powder in paper sacks. We did store some allergen containing products over other but only in the case where the same allergens were within those products. Appropriate spill and cleaning procedures in place of course. I will mention though that I haven't reviewed S&D since I left there in 2016 so would check for any relevant update.