Segregated allergen storage
After many years of running as an allergen free facility, my company has now decided to start producing a product that contains wheat gluten by way of beer. Our plan is to bring in only the amount that we need to complete a run in sealed plastic totes, but store any leftover open totes until the next run. Some people are suggesting allergen labeling and storage in a gated, locked area with spill containers for each tote. Others suggest allergen labeling and storage in a gated locked area, but just surrounding the gated area with spill blocker pigs or absorbent booms. While yet others just want to sticker the totes.
What are the rest of you doing for segregated storage of allergenic liquid product?
We use separate pallets and put allergens at the lowest rack in storage. Works for us (Juice production BRC AA).
After many years of running as an allergen free facility, my company has now decided to start producing a product that contains wheat gluten by way of beer. Our plan is to bring in only the amount that we need to complete a run in sealed plastic totes, but store any leftover open totes until the next run. Some people are suggesting allergen labeling and storage in a gated, locked area with spill containers for each tote. Others suggest allergen labeling and storage in a gated locked area, but just surrounding the gated area with spill blocker pigs or absorbent booms. While yet others just want to sticker the totes.
What are the rest of you doing for segregated storage of allergenic liquid product?
Hi Jess,
You omitted to mention if any FS standard involved.
I think most (all?) GFSI-recognised FS standards require segregation.
How much segregation in theory relates to your risk assessment. In practice, IIRC, some standards specify a minimum degree of segregation.
"Separate locations" is typical, but the "judgement" of what constitutes "separate" is different by most people. Coming from a facility that had all the big 8 allergens, in both liquid and dry, we had to continual modify our allergen control program as it relates to storage for every customer audit or third-party audit. It was quite comical because in every audit the auditor was not 100% satisfied.
We had only ONE instance of allergen cross contact, and that wasn't a storage problem, it was a production sequence problem. We caught it easily before the product was even finished producing.
While I understand the risk as it relates to allergen recalls being the highest in number in the US, sometimes I think what some auditors see as the actual "risk" is overkill in most cases. Specifically, the most troubling seem to come from customer audits. They all have different requirements, and some are quite extreme as it relates to the actual risk in a facility.
However you do it, make sure you fully assess the risk and be able to provide/show how you are controlling that risk...the stronger the better, but bear in mind you will likely have to change/modify your program to suit different auditors.
Considering that your facility has been allergen free I would go for the maximum protection for this item. Plus a question pops into my head since we also do Gluten-Free consulting; namely do you produce any product that is Gluten-Free? an if so, are you doing a risk analysis for the potential of exposure of gluten, drift, etc?
Thank you all for your input!
We are a BRC certificated plant and I feel pretty confident that our risk assessment as well as our corresponding systems support compliance in this area. Unfortunately, like Ryan said, customer audits seem to be the most troubling because they all seem to want something different.
Thank you all for your input!
We are a BRC certificated plant and I feel pretty confident that our risk assessment as well as our corresponding systems support compliance in this area. Unfortunately, like Ryan said, customer audits seem to be the most troubling because they all seem to want something different.
Yup...it is basically a guessing game to see what customer "asks" for specific protocols or requirements. I make it a comedy whenever a customer auditor asks us to change up our allergen program. "You're the 4th one this year!"