Distribution of hazardous chemicals

Hello!

First post, so please bear with me. My facility is working through preparations for our first SQF audit against v8. We have a combined distribution and commissary facility, this question relates specifically to the distribution side. Our DC services our convenience retail outlets, which carry hazardous chemicals for use and sale (fuel additives, windsheildwasher fluid, motor oil, etc.) as convenience items in addition to foods, etc. We are encountering a puzzle which we have been discussing since our facility opened, and that is: based on available pick path locations and hazard storage locations (appropriate fire sprinkler coverage) we do not seem to have enough room for reserve pallets of case packed chemicals that are destined for our retail outlets to not be stored above pick slots of items such as soda bibs and cases of bottled drinks. Ideally we would store only food items above food items and likewise for hazardous chemicals. Our current procedures call for anything food affected by a hazardous spill would be discarded, no question. Regardless, I'm trying to figure out if it will be an issue during our audit, and I would appreciate any assistance.

Module 12 (12.6.5.1) states:

"Hazardous chemicals and toxic substances that are for use in the site with the potential for food contamination shall be stored separate from the distribution storage area so as not to present a hazard to staff, product, packaging, product handling equipment. Hazardous chemicals shall be stored in their original containers, or in clearly labelled secondary containers if allowed by applicable legislation."

The chemicals used "in the site" are stored separately and sufficient distance away, but it does not really mention chemicals that are not for use in the site unless I am misinterpreting "use". 

We are currently budgeted to expand our sprinkler system to add more in-rack hazard storage, but there is not yet a timeline around it.

Ultimately: Do we need to move product around so that hazardous chemicals are not above any food items (bottled drinks, etc.)? Would a risk assessment, programs to address spills, and employee training be sufficient instead?

Would be happy to provide clarification or additional information as needed. 

Thank you for your assistance!

Hazardous chemicals and toxic substances that are for use in the site with the potential for food contamination

 

I think that specific wording is your way out here. I would prepare a formal risk analysis of the risk of spillage from your chemicals. If you can establish that (under normal controls) the chemicals do not have the potential for food contamination, and they aren't in use at your facility I think you may be okay. This is similar to the language in 2.3.2.1 which talks about specs for hazardous chemicals, but again states that it only applies to those not intended for distribution but actually in use on site. If you actually put together a plan/timeline to extend your sprinkler system and remove the issue, you could prepare that timeline and take advantage of 12.6.6 which allows for temporary alternative storage in non-ideal conditions.

In the event of a disagreement with an auditor, it's worth noting that the language of the code is specifically different between a the manufacturer and distributor versions of the code:

Manufacturer:

11.6.4.1 Hazardous chemicals and toxic substances with the potential for food contamination shall be stored so as not to present a hazard to staff, product, packaging, product handling equipment or areas in which the product is handled, stored or transported.

 

Distributor:

12.6.5.1 Hazardous chemicals and toxic substances that are for use in the site with the potential for food contamination shall be stored separate from the distribution storage area so as not to present a hazard to staff, product, packaging, product handling equipment. Hazardous chemicals shall be stored in their original containers, or in clearly labelled secondary containers if allowed by applicable legislation.

 

Addressing this part:

Ultimately: Do we need to move product around so that hazardous chemicals are not above any food items (bottled drinks, etc.)? Would a risk assessment, programs to address spills, and employee training be sufficient instead?

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You can't store chemicals above food products - you need total separation.