Requirements for co-packing pre-cut cheesecakes
So, first off my apologies if I posted this in the wrong forum / section.
Given the current government shutdown, I cannot pose this question to my FDA contacts (I tried, I received an automatic reply that they are furloughed).
Recently, our sales team has been trying to expand our offerings by looking at selling single slices of our cheesecake to convenience stores. We really are not set-up, nor do we have the space to currently packaged and store frozen single slices. Therefore, our sales team is looking into their party co-packing options.
What would be your insight and recommendations to sending our frozen, pre-cut cheesecakes to a third party, who would package them into single slices? Are there certain parameters or items that should be addressed? We are subject to FSMA, and do not have any GFSI certifications.
The "option" (if you even want to call it that) that our sales team has come up with makes me cringe and want to cry. The very abridged version is selling our cakes to a broker's son's restaurant (on rolling racks unpackaged because he doesn't want to deal with opening boxes), who will pack them during off hours in a produce warehouse owned by a family friend of his. Fortunately, management is on board with me and agrees this poses many questions / red flags, but sales does not see anything wrong with this and will not let it go. They cannot see how that is any different than a grocery store repacking our product into single slices.
Any auditor insight or codified law references would be much appreciated!
food-safety-issue-8-checklist-english.docx 138.06KB 7 downloads
Completely understand your perspective - how many of us haven't had "differences of opinion" with sales personnel who think copacking is a matter of cost/convenience & quality is merely a matter of ticking some boxes?!
As I high risk product I would share your concerns 100%....and as the manufacturer/vendor you would bear the liability if something goes wrong as the copacker is considered to be your supplier..
Although you are not GFSI there is guidance for this in BRC 8 (attached) which is a good starting point for what you need to look out for (see section 9.1 copackers & 3.5.3 service suppliers)
Best of luck!