Reviewing the standard I got a basic question, does a storage and distribution site has "food contact surfaces"?
It varies from Warehouse practices, if you are repackaging any of your products/ exposing the product out of the primary packaging (example breaking a bulk flour bag into various smaller/private label bags and the product is exposed) you will require to maintain a sanitary food contact surface to perform this function. If your practice is just receiving, storing and distributing the product , without exposing the product at any point in your facility, you do not have direct food contact surface, as the finished products are already inside secondary or tertiary packaging by the processor/manufacturer (keep in mind that regular cGMP/GDP should be maintained example no product on the floor).
Then if the answer is negative, how different is a "food contact surface" from a "exposed food packaging"?
Special consideration should be given in your fresh produce storage area, as any condensation on the product could be a critical. Proper cGMP/GDPs should be followed in this area.