Allergen Program in a refrigerated distribution center

I currently work in a distribution center that supplies food to large supermarkets and many types of restaurants. Our current allergen management program has a constantly updated list of all current allergens in stock (everything is individually packaged, box in box out). A previous third party auditor (before my time) strongly suggested we color code and label all allergens in the pick slot. 

My question is, does anyone see any logic in that? I don't..

The items constantly move throughout the facility, we tend to order based on customer need and stock as little as possible. As I said, everything is box in/box out (we are NOT manufacturing). I asked the current PCQI why the heck the auditor said we need to label the pick slot for allergens, her reply was "maybe so the employees know there are allergens in case they are allergic."

Can anyone here see a need why we should continue this process? I came in with a "let's do what we say we do" goal, and we are currently not doing that. 

In a DC it is more from a standpoint of potential cross contamination. 

Example would be how you store items containing allergens, e.g. peanuts with peanuts, tree nuts by themselves, soy with soy, how do you stack,etc.

It is not because an employee might be allergic to an item.

You are of course joking about what the PCQI said, if not... yikes!

Having DC's as clients most segregate and color coding is in use in many, this does however get a bit sticky when you have items containing multiple allergens.

About the response from both PCQI's, no not a joke. All of our items are sealed and packaged, basically how you get it at the grocery store is how it comes through us, even our "bulk" is bagged and on pallets. We have multiple items with multiple allergens, to seperate or even keep them in individual locations would be logistically improbable (approximately 3 pages full using greenbar print paper). To add to the issue, nothing stays in stock long. It's in and out <3 days for 70%-80% of all sales, and what we have going through constantly changes.

My thoughts on a plan of action is to sit down with the food safety team and revisit the hazard analysis on allergens. If the team feels the hazard is negligible (as I do, most of the items are double sealed) then we will remove the color coding scheme (that we say we follow but don't). If the team feels there is a chance for cross contamination, we will have to step it up and figure something out. They were told they needed to do something from a third party auditor and jumped at doing it without looking at it using common sense.

Dear TimGoss

Maybe a thoroughly risk based and sufficient implemented spill procedure would do the trick for you.

In the case of observed spilling there might be a risk. A very small one because the damaged pack will probably destroyed and the other packs are also primary and secondary packed. To know which allergens are involved and how to handle might be a practical solution.

Please also check the requirements of your customers. These might be give you no space to own interpretation.