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Allergen management in a shared facility

costco allergen audit food safety

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#1 Foodprep

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Posted 05 June 2021 - 04:50 PM

Hello,

 

We are a small business running out of a shared facility. We make plant based and meat soups. We are hoping to land Costco as a customer.

 

Here's our confusion: There are two other business on the same side as us. There is no physical separation between each business    (every business has their own equipment, shelves, racks etc, which kind of makes a boundary). Both of our neighboring businesses contain allergen products, 1 contains milk and the other contains flour.

All 3 of us use the same production sink to wash utensils or dishes etc. i.e. there is no employee flow control. Our product label contains "May contain" for all allergens that are present in the facility. I am wondering if this is an acceptable control measure for allergen controls. I don't think so. I think if we want Costco, we may have to look into major production rescheduling where we are not operating at the same time the other guys are. Based on the structure of the facility, it is not possible to create a physical separation. 

 

Main concern is production because raw material and finished product can be closed/covered during storage. 

 

Given the current scenario, is it worth thinking about Costco? Any suggestions for allergen management.  

 

Thanks,

K



#2 SQFconsultant

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Posted 05 June 2021 - 08:47 PM

We were approached some years back by a company that shared space with 4 other companies in a food manfacturing incubator. The potential client wanted to go SQF and SQF (As most others will).can do a multi use facility but only as a whole unit and not in parts. It would be better if you found a good spave to work out of that was independent of others because the issue becomes that companies leave and companies join the mix and each time modification of the whole is needed. And generally speaking from first hand knowledge Costco will not tolerate your type of shared facility... thus I would be starting a search now for a new place.


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#3 olenazh

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Posted 07 June 2021 - 12:27 PM

Costco has their own standard, and you should first study it prior to making any decision. They're pretty strict and picky: we've been working with Costco for several years. I'm attaching their standard - but I'm not sure it's the latest version, though it could give you some idea.

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#4 Scampi

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Posted 07 June 2021 - 12:50 PM

Allergens.......do you currently have a statement on your packaging that it is produces in a facility that has those allergens?  Even without Costco, you have an obligation under SFCR to mitigate the allergen contamination if you are currently shipping between provinces/territories

 

 

 

Be careful when pursuing Costco, 1) they will not pick up your product is they will represent the lions share of you business financially

                                                        2) if you spend big bucks to meet their expectations, and your products do not sell, the will drop you like a hot potato

                                                        3) they probably will not take your product manufactured in a shared facility

 

I'd be shooting for someone like Farm Boy instead---they are a dream to work with and love taking homegrown products on as private label


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#5 MDaleDDF

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Posted 07 June 2021 - 03:19 PM

This is an odd one. I've personally never heard of a shared facility.   Could you isolate more in any way?   I stack every product I make here.   There are 4 allergens in my building:  Wheat, Milk, Egg, and Soy.   When we first started all our NSF stuff, I put all 4 in everything.   So if a product has 3, but is missing egg, I add a tiny bit of egg, so everything has all 4, no cross contamination, voiala.   Obviously it would be adding allergens to your process which may suck depending what you're doing and how, and it sounds like maybe your neighbor is temporary possibly?   Hard fix here.... I agree that finding your own space is really the best answer long term, though it's not an easy one.



#6 Foodprep

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Posted 07 June 2021 - 07:34 PM

Costco has their own standard, and you should first study it prior to making any decision. They're pretty strict and picky: we've been working with Costco for several years. I'm attaching their standard - but I'm not sure it's the latest version, though it could give you some idea.

Thank you for the attachment. I have already reviewed this document. It doesn't talk a lot about allergen standards at Costco. 



#7 Foodprep

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Posted 07 June 2021 - 07:36 PM

This is an odd one. I've personally never heard of a shared facility.   Could you isolate more in any way?   I stack every product I make here.   There are 4 allergens in my building:  Wheat, Milk, Egg, and Soy.   When we first started all our NSF stuff, I put all 4 in everything.   So if a product has 3, but is missing egg, I add a tiny bit of egg, so everything has all 4, no cross contamination, voiala.   Obviously it would be adding allergens to your process which may suck depending what you're doing and how, and it sounds like maybe your neighbor is temporary possibly?   Hard fix here.... I agree that finding your own space is really the best answer long term, though it's not an easy one.

We rent a station in a Commercial Kitchen. We are a small business so, can't afford our own facility at this time. 

Thanks for your ideas. 



#8 johnmcip

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Posted 07 June 2021 - 07:39 PM

This is an odd one. I've personally never heard of a shared facility.   Could you isolate more in any way?   I stack every product I make here.   There are 4 allergens in my building:  Wheat, Milk, Egg, and Soy.   When we first started all our NSF stuff, I put all 4 in everything.   So if a product has 3, but is missing egg, I add a tiny bit of egg, so everything has all 4, no cross contamination, voiala.   Obviously it would be adding allergens to your process which may suck depending what you're doing and how, and it sounds like maybe your neighbor is temporary possibly?   Hard fix here.... I agree that finding your own space is really the best answer long term, though it's not an easy one.

 

That is a very strange way to handle it. Could you not just put the disclaimer on the packaging for the ones it doesn't contain? so if you make something with wheat and milk add "contains egg and soy" to the packaging. I don't think this would be adulteration as its both precautionary, and will probably contain trace amount of them.



#9 olenazh

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Posted 07 June 2021 - 07:40 PM

As the previous guys said, think twice before starting business with such big guys (e.g. Costco, Metro, Loblaw), your expenses might not be worth of the profit. And secondly, AFAK from my experience of working with many of these chains - they might be very rude in terms of terminating projects without notification and such things. 



#10 Ryan M.

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Posted 09 June 2021 - 01:38 PM

That is a very strange way to handle it. Could you not just put the disclaimer on the packaging for the ones it doesn't contain? so if you make something with wheat and milk add "contains egg and soy" to the packaging. I don't think this would be adulteration as its both precautionary, and will probably contain trace amount of them.

 

FDA doesn't allow disclaimers for "just in case" scenarios like this.  They require you do proper labeling and take all necessary precautions to prevent allergen cross contact.  I think the way MDaleDDF handled it is actually brilliant.  However, this is always a tough sell with management and customers because it adds cost for no "apparent reason".  On the flip side, if you can show the cost savings of not having to schedule production in a specific way, not have to do additional cleaning and other practices then the added ingredient cost to a product is likely a wash.  Not only that, you significantly reduce your liability.

 

 

 

 

 

#11 Scampi

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Posted 09 June 2021 - 03:45 PM

I'm guessing your not SFCR inspected, based on the shared commercial kitchen rental

 

FYI food prep, Costco REQUIRES inspection (federal or provincial) and they will not touch you without it, and you will not be able to get inspections in a rental space

 

I'm assuming you're at the cottage industry level at the moment?


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#12 Foodprep

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Posted 09 June 2021 - 04:41 PM

I'm guessing your not SFCR inspected, based on the shared commercial kitchen rental

 

FYI food prep, Costco REQUIRES inspection (federal or provincial) and they will not touch you without it, and you will not be able to get inspections in a rental space

 

I'm assuming you're at the cottage industry level at the moment?

We are not inspected by CFIA at the moment because we don't sell out of province however, we are in the process of having them over. I am working on the HACCP plan updates that CFIA recommended after their first HACCP Plan review. We get Food Safety audit by third party (NSF) every year . It was simple a couple months ago when we had no neighbors. We had one big side of the facility to us. New tenants came recently. Our CFIA review started prior to new tenants so, their activity/ flow was not part of my HACCP. I guess I will have to contact them and see if they want me to make updates to the program based on our neighbors. 



#13 Scampi

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Posted 09 June 2021 - 04:52 PM

Yes, you're going to have to update your documentation for the flow diagrams as well as allergen management----CFIA considers it a chemical hazard, so you're going to have to have mitigating procedures in place

 

If you're not currently shipping out of province, why not start with becoming provincially inspected???  It's a great primer to the next step---most provinces have some grant money available for food safety, and the new fiscal year has either just started or is about too


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#14 olenazh

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Posted 09 June 2021 - 05:00 PM

Yes, you're going to have to update your documentation for the flow diagrams as well as allergen management----CFIA considers it a chemical hazard, so you're going to have to have mitigating procedures in place

 

If you're not currently shipping out of province, why not start with becoming provincially inspected???  It's a great primer to the next step---most provinces have some grant money available for food safety, and the new fiscal year has either just started or is about too

Hey Scampi, could you please share details of that "grant money" if you don't mind? Sounds intriguing and I know nothing about that. 



#15 MDaleDDF

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Posted 09 June 2021 - 06:00 PM

That is a very strange way to handle it. Could you not just put the disclaimer on the packaging for the ones it doesn't contain? so if you make something with wheat and milk add "contains egg and soy" to the packaging. I don't think this would be adulteration as its both precautionary, and will probably contain trace amount of them.

As already stated, that won't work, no.   There's also way more to it, such as cross contamination, cleaning between batches, segregation of ingredients, etc.   Trust me, what I do makes life much much easier for everyone here.   We actually save money in the long run, and as far as customers, it's very simple:  if you have a problem with those 4 allergens, we won't make your product, and if your product will introduce a different allergen to us, you'd better be talking to me about millions of pounds, or I don't want your business.

After they added celery in Europe, I had to remove all celery from the facility, and now I use a celery flavor.  I don't mess about with allergens.  Did you know over 50% of recalls involve allergens?  No thanks!



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