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SausageGuy

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Posted 06 July 2020 - 03:01 PM

Good morning, all!

 

 

The company I work for is SQF certified and we manufacture and sell raw pork sausage and poultry sausage. I have written us an allergen program as per section 2.8.1.11 because we are an allergen free facility. We have a couple contract manufacturers who produce fully cooked sausage for us. The sausage is "box in, box out" with no exposed RTE product in our facility. Per our allergen program, even our fully cooked offerings are allergen free. We now have a high volume customer that would like us to provide them with a private label fully cooked product; the problem is the product contains TVP and we are an allergen free facility. I know I can rewrite our allergen program based on this new product, but I need a little clarification as to how to interpret the code.

 

2.8.1.2 Instructions shall be provided to all relevant staff involved in the receipt or handling of raw materials,
work-in progress, rework or finished product on how to identify, handle, store and segregate raw materials
containing allergens.
 
Does this include segregation of of finished products, even products we don't manufacture?
 
2.8.1.3 Provision shall be made to clearly identify and segregate foods that contain allergens. Segregation
procedures shall be implemented and continually monitored.

 

Can segregation be a separate rack for pallets of finished products containing allergens, or do we need a physical barrier to separate products with allergens? All product stored in our freezer is finished product that is packaged and ready for sale, and there are no raw materials present in this cooler.

 

Part of the Implementation Guidance states:

Sites must establish the allergen status of incoming materials and ingredients and have procedures in place to isolate
and control materials and products containing allergens
 
Again, what is the definition of isolate here? With a physical barrier, or just separate storage within the same freezer?
 
I had a SQF auditor tell me a few years ago that products containing allergens must be stored completely separate from products not containing allergens.
 
Any insight or suggestions would be greatly appreciated.
 
 
Thanks!

Edited by SausageGuy, 06 July 2020 - 03:02 PM.


olenazh

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Posted 06 July 2020 - 03:18 PM

Ingredients, containing allergens, could be separated from other ingredients, containing other allergens, by storing them BESIDE each other, not ABOVE, to prevent contamination/cross-contamination by spillage. However, you could store non-allergens ABOVE allergen-containing ingredients as there's no risk of contamination. If you don't have enough space for complete segregation, you could store allergen-containing ingredients above multi-allergens: for instance, soy-containing ingredient could be stored above soy & wheat-containing one, etc. We practiced this at the bakery (BRC certified) having 100+ ingredients, and got no objections from the auditor.



SQFconsultant

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Posted 06 July 2020 - 03:55 PM

Good morning, all!
 
 
The company I work for is SQF certified and we manufacture and sell raw pork sausage and poultry sausage. I have written us an allergen program as per section 2.8.1.11 because we are an allergen free facility. We have a couple contract manufacturers who produce fully cooked sausage for us. The sausage is "box in, box out" with no exposed RTE product in our facility. Per our allergen program, even our fully cooked offerings are allergen free. We now have a high volume customer that would like us to provide them with a private label fully cooked product; the problem is the product contains TVP and we are an allergen free facility. I know I can rewrite our allergen program based on this new product, but I need a little clarification as to how to interpret the code.
 
2.8.1.2 Instructions shall be provided to all relevant staff involved in the receipt or handling of raw materials,
work-in progress, rework or finished product on how to identify, handle, store and segregate raw materials
containing allergens.
 
Does this include segregation of of finished products, even products we don't manufacture?

 
>> YES.
 

2.8.1.3 Provision shall be made to clearly identify and segregate foods that contain allergens. Segregation
procedures shall be implemented and continually monitored.

 
Can segregation be a separate rack for pallets of finished products containing allergens, or do we need a physical barrier to separate products with allergens? All product stored in our freezer is finished product that is packaged and ready for sale, and there are no raw materials present in this cooler.


>>> So, I am assuming it comes in already boxed up (sealed) - you'll need to segregate it, mark it as containing SOY - that does not mean however that you need to build a physical barrier - you can store the boxes next to other - not touching and not over others.
 

Part of the Implementation Guidance states:
Sites must establish the allergen status of incoming materials and ingredients and have procedures in place to isolate
and control materials and products containing allergens
 
Again, what is the definition of isolate here? With a physical barrier, or just separate storage within the same freezer?

>>> separation, marking the allergen - I have a client, same situation - they mark with black SOY letters on green background labels that go on all the outter wraps an pallet.
 
 

I had a SQF auditor tell me a few years ago that products containing allergens must be stored completely separate from products not containing allergens.


>>> it fully depends on the situation and not all situations are the same - I have a client with an alergen free facility, but once they brought in same kind of thing as you are doing they decided to get a separate cooler set up right off the receving area so the only allergen never got into the building fully - but you still need to set up your documentation and procedures for the WHAT IFS.

All the Best,

 

All Rights Reserved,

Without Prejudice,

Glenn Oster.

Glenn Oster Consulting, LLC -

SQF System Development | Internal Auditor Training | eConsultant

Martha's Vineyard Island, MA - Restored Republic

http://www.GCEMVI.XYZ

http://www.GlennOster.com

 


Simon

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Posted 06 July 2020 - 06:09 PM

Tip Glenn, give the MULTI QUOTE button a try when replying as per above.


Get FREE bitesize education with IFSQN webinar recordings.
 
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SQFconsultant

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Posted 06 July 2020 - 06:21 PM

ahh, that's how it works - thanks simon!


All the Best,

 

All Rights Reserved,

Without Prejudice,

Glenn Oster.

Glenn Oster Consulting, LLC -

SQF System Development | Internal Auditor Training | eConsultant

Martha's Vineyard Island, MA - Restored Republic

http://www.GCEMVI.XYZ

http://www.GlennOster.com

 




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