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21 CFR 117.93 Warehousing and Distribituion

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Posted 15 March 2019 - 08:54 PM


§ 117.93 Warehousing and distribution.

Storage and transportation of food must be under conditions that will protect against allergen cross-contact and against biological, chemical (including radiological), and physical contamination of food, as well as against deterioration of the food and the container.




My search for understanding:


  • What is the best practices and methods of picking and loading products onto a pallet that are both allergenic and non-allergenic (together/co-mingled)?
  • Bear in mind that in some instances allergenic materials may not be able to be placed on the bottom of the pallet in order to prevent cross-contact because of stability of the pallet.
  • In the beverage industry this is an issue. What can be done to overcome this? What is acceptable and best practice? 



Review this thinking: A milk-containing beverage (Let's say Dunkin Donuts Coffee) can be picked and placed on a pallet above a CSD without fear of leakage as long as the allergen is identified and is modified to be spill-preventive.



Looking for advice as well as if this is the only regulation outlining any guidance in regards to distribituion centers shipping allergens and non allergens together to their final destination (typically retail store, Hy-Vee, etc). Where they will then suddenly be allowed to to place these allergenic products right next to non-allergenic products on shelves

Edited by jdpaul, 15 March 2019 - 08:56 PM.


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Posted 18 March 2019 - 05:09 AM

Hi jdpaul,


Best practice would not to mix but that can be somewhat impractical.


First of all I assume that the product are sealed, presumably there is secondary packaging for transport/protection as well.


Additional controls would be adequate protection from damage on the pallet if needed (for example layer pads), spillage controls and inspections.


Kind regards,



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