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Clarifying Conflicting Allergen Policies


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#1 kairi26

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Posted 15 January 2021 - 06:49 PM

I'm fairly new at my company, and I'm currently trying to sort through conflicting documents/institutional knowledge regarding allergen storage. I work at a 3rd party storage facility that handles packaged and labeled product belonging to our customers. The previous food safety manager had written an allergen policy that prevents storing allergens above non-allergens, but does not address horizontal separation. A different document I found that is not part of our official SOPs (but has been used for training in the past) says that allergens must be stored a pallet width apart from non-allergens/other allergens. This rule is commonly referenced by long time employees, and is assumed to be a requirement despite not being in our food safety plan. The leadman in charge of our dry storage area is having a hard time finding room for all of the various products we've received while maintaining allergen segregation, so we are trying to clarify whether or not the 1 pallet space gap needs to be maintained. Is there any literature I can reference to help us decide what direction to go with our allergen management policy? We are in the US and SQF certified for Storage and Distribution. 



#2 olenazh

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Posted 15 January 2021 - 07:30 PM

Sorry, I have no reference literature, however skid apart sounds too much separation. It's common sense: if you store allergen & non-allergen (or different allergens) beside each other provided they are packed properly and are not leaking/spilling - that would be completely sufficient. I've had that policy at all places I worked for, having different certifications, including BRC & FSSC, and it's always been acceptable by the auditors and even government inspectors.



#3 Scampi

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Posted 15 January 2021 - 08:02 PM

Can you at least zone 1 area of the warehouse for allergen storage and non allergenic materials in a separate zone???  Then you could have say an area for "tree nuts" one for "gluten" etc

 

Wouldn't that be easier than trying to juggle space vs allergens???


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#4 Charles.C

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Posted 16 January 2021 - 02:48 AM

I'm fairly new at my company, and I'm currently trying to sort through conflicting documents/institutional knowledge regarding allergen storage. 

 

I work at a 3rd party storage facility that handles packaged and labeled product belonging to our customers. The previous food safety manager had written an allergen policy that prevents storing allergens above non-allergens, but does not address horizontal separation. 

 

A different document I found that is not part of our official SOPs (but has been used for training in the past) says that allergens must be stored a pallet width apart from non-allergens/other allergens. This rule is commonly referenced by long time employees, and is assumed to be a requirement despite not being in our food safety plan.

 

The leadman in charge of our dry storage area is having a hard time finding room for all of the various products we've received while maintaining allergen segregation, so we are trying to clarify whether or not the 1 pallet space gap needs to be maintained.

 

Is there any literature I can reference to help us decide what direction to go with our allergen management policy?

We are in the US and SQF certified for Storage and Distribution. 

 

Hi kairi,

 

This is a frequently discussed topic on this Forum with regard to various FS Standards. Recalls due allergen-related "defects" are of high-frequency occurrence in USA

 

If you look through SQF Guidance there is a "ton" of textual allergen-related material but I could not see any  specific details  regarding  "segregation". Similarly for other Standards. .

 

At least 2 other aspects so far unmentioned in this thread are important - (1) Risk assessment for cross-contamination, (2) allergen Labelling.

 

Previous threads here include experiences regarding segregational expectations, some Literature references, and comments on (1,2) above.

 

Here are a few (long and short) examples, not necessarily SQF-

 

https://www.ifsqn.co...ens/#entry67286

https://www.ifsqn.co...ity/#entry88248

https://www.ifsqn.co...ge/#entry110371

https://www.ifsqn.co...ng/#entry105072

https://www.ifsqn.co...es/#entry114037

https://www.ifsqn.co...ls/#entry112841


Kind Regards,

 

Charles.C


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#5 crudder6

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Posted 20 January 2021 - 06:34 PM

As long as the pallets are wrapped, side by side is fine. Never store an allergen above a non-allergen. You can however store a non allergen above an allergen. Think of gravity when you store allergens. If a product is damaged, where is it going to fall. You want to concentrate on vertical storage, not horizontal storage.



#6 Ryan M.

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Posted 20 January 2021 - 10:23 PM

Hello risk assessment!  You need to assess your risk with the material integrity being compromised (breaking open, spilling, etc).  And then assess the risk of that making cross contact to non-allergen or different allergen materials.

 

Ideally you have segregated and identified with labels / posting allergen zones within the racks, but a pallet worth of separation not necessary unless you determine "high risk".  Some places put barriers between the racks to address horizontal cross contact, which is overkill in my opinion, but again is dependent on your risk assessment.

 

Every facility I've been at does not use a pallet width separation.



#7 Charles.C

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Posted 21 January 2021 - 12:41 AM

I'm fairly new at my company, and I'm currently trying to sort through conflicting documents/institutional knowledge regarding allergen storage. I work at a 3rd party storage facility that handles packaged and labeled product belonging to our customers. The previous food safety manager had written an allergen policy that prevents storing allergens above non-allergens, but does not address horizontal separation. A different document I found that is not part of our official SOPs (but has been used for training in the past) says that allergens must be stored a pallet width apart from non-allergens/other allergens. This rule is commonly referenced by long time employees, and is assumed to be a requirement despite not being in our food safety plan. The leadman in charge of our dry storage area is having a hard time finding room for all of the various products we've received while maintaining allergen segregation, so we are trying to clarify whether or not the 1 pallet space gap needs to be maintained. Is there any literature I can reference to help us decide what direction to go with our allergen management policy? We are in the US and SQF certified for Storage and Distribution. 

 

Specific recommendations re horizontal requirements are rare although a quantitative requirement is designated in one of the links in Post 4. However IMO it seemed  likely to be unworkable from a practical POV.

.

I reiterate a recommendation to at least read the 1st link in Post 4.


Kind Regards,

 

Charles.C





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