During our BRC/IFS Food audit, we received the following NC: the hazard analysis does not take into account the possible storage in the same cold room of fruits and vegetables/various packaging/spare parts or parts of packaging material.
Whoever has experience in the fruit and vegetable sector knows that fresh fruit and vegetable are generally stored on pallets with 100-200 carton/plastic boxes (sometimes fully covered) of either loose product (lets say 5 kg of loose cherry tomatoes in a box) or pre-packed product (10 punnets of 500 g strawberry). And in most of the cases on the top of this pallet you also have a pallet cover for extra protection. The packaging material is packed in closed carton boxes; all packaging material of the same type are stored on the same pallet. We are aware of the fact that product and packaging material should be stored separately in different storage rooms, but we always have the audit during the peak of the season, when all extra square meter is necessary.
I started doing the hazard analyses and my first question was what kind of contaminants can I have?
- microbiological: the probability that there will be a cross-contamination from the pallet with packaging material is just the same like from the one with product. I would say that the one from the other product is even higher: if the product is already class 2 and with mold, then you have with what to have the cross-contamination. At a butcher or a slaughter house, I can imagine that the carcasses are not stored in the same cold room with all the packaging material, but for fruit and vegetable (low risk) I don't see any problem.
- chemical: I also don't see what kind of chemical contaminants can get from the pallet with packaging material to the one with product. Of course, migration of packaging material is discussed in the HACCP plan at general hazards
- physical: there might be contaminants on the boxes with packaging material: plastic, metal, wooden pieces, which could fall during the transport of the pallets and contaminate the product. But I can't figure out anything else.
And a last possible contaminant: feces of pests on boxes with packaging material which could fall in the product. And in this case besides physical, I would also go for microbiological contamination.
Does anyone have another idea or doesn't agree with my way of seeing the hazards?