Allergen Segregation For Finished Packaged Goods

Hello Everyone,

My company is an importer/ distribute of finished packaged goods. 

We receive allergens (soy protein, milk products, wheat/corn flakes, tea, infant formula and so on.)

In my allergen SOP I mentioned allergen stickers/tags for incoming shipment to be affixed to each pallet.

I wanted that to be a CCP or control measure for allergen segregation. Other control measures would be flagging allergen on WMS, separate area for allergen storage.

If i do a risk assessment and show that since products arriving are finished product goods and leaving the same way, there is low to negligible risk of allergen contamination, can I do do without allergen stickers or tags?

comments,/ suggestions much appreciated!!

thank you so much,

Anika R

You could do without tags, but my experience with warehouse workers is that they really don't care where they put stuff. We've had many workers know the policy, yet put an allergen over a non-allergen. When they run out of space, better believe they'll forget the rules. I'd also be cautious about using this as a CCP. You can certainly use it as a CP.

We started using allergen tags so our employees couldn't say they didn't know or they forgot the product was an allergen. It's a lot easier to see instances of procedural failures. 

Also, just because you're handling finished goods doesn't mean the potential for contamination isn't there. This is especially the case for powdered allergens. Forklift punctures to products result in a bad time for all involved in the cleanup. The labeling enforces proper placement of your products, so if there is a spill, at least its hopefully "like" product. I'd vote for keeping the labels/tags.

Thank you QAGB!

I want to keep the Allergen tags as well. its going to be difficult to convince management. They are new with Food management.

I'm going to continue to try to convince them.

I like to take the thinking out of the warehouse personnel while on the floor and just have visual aids like tags/stickers. 

Maybe i can suggest a process where it wouldnt hold up dock space

Thank you

Anika

Once I have a declared allergen, the risk goes up considerably just because of the possible outcome with a cross contamination. Unlike a few others "risks" in the plant where it might just result in a dissatisfied customer; with allergens, I have to look at worst case scenario, and that is hospitalization or worse.

I would NOT make it a CCP as that would involve far more than what it sounds like your operation needs, however in my opinion a CP is necessary based on what you described. QAGB covered all the main reasons (we must have the same warehouse employees). The more you can show and verify that you are controlling your allergens the better off you will be. Tags are an excellent way for people to quickly identify and group like products, even busy warehouse employees.