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Major NC- Allergen Separation in Warehouse


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AltonBrownFanClub

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Posted 09 September 2021 - 04:22 PM

We recently completed an NSF supplier audit and were dinged for a major nonconformance on allergen storage.
 

The products are sealed bottles/packets of sauce. They are in individual containers, sealed cardboard cases, and in some cases additional plastic wrap around the cases. They are stored on pallets near each other.

 

The inspector suggested putting up pallet racking and making each shelf dedicated to a specific allergen. Not only is this not financially attainable, but we have many ingredients with complex and differing allergen profiles.

I have created zones with colored floor tape for products with single or no allergens. The others are stored on shelves with the best spacing I can manage. (For example: Wheat on top shelf, wheat & soy on middle shelf, and wheat, soy, & fish on the bottom shelf.

My question is this: Is this sufficient? The risk assessment for cross-contact was very low. They stay on the pallets until packed and shipped elsewhere.

 

Should I explore plastic barriers for between the pallets? Is there a required distance? 

 

I totally understand the concern for allergen safety. I initiated sesame labeling on all products when I was hired. This seems a little excessive imho. Especially for ingredients that will eventually be packed and shipped together on the same pallet.



olenazh

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Posted 09 September 2021 - 04:52 PM

Your system of allergen separation, including those on top of each other with descending order of multiple allergens, is completely sufficient. When I had a BRC audit, done by NSF, I did exactly the same as we had a lot of multiple allergen items, and our storage area didn't allow to place every individual item separately. That system of ours was satisfactory to NSF auditor and BRC code as well. As I'm aware of, the auditors' comments should be reasonable depending of the company resources, budget, space availability and other company-specific factors. I'd object the NC if I were you.


Edited by olenazh, 09 September 2021 - 04:53 PM.


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AltonBrownFanClub

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Posted 09 September 2021 - 08:15 PM

Great, thank you. The inspector gave us some other great advice, but this is one bit that I did not agree with. 
 

It stung since it was one of the few things I have "control" over. The other non-conformances, although important, were not related to my oversight.

I am hoping a good score on the next inspection will prove my abilities and earn some respect. I have had a lot of work to do.

My biggest fear is I will be blamed for poor results and/or not credited for improvement. Guess we will see! 


Edited by AltonBrownFanClub, 09 September 2021 - 08:15 PM.


olenazh

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Posted 09 September 2021 - 08:52 PM

Great, thank you. The inspector gave us some other great advice, but this is one bit that I did not agree with. 
 

It stung since it was one of the few things I have "control" over. The other non-conformances, although important, were not related to my oversight.

I am hoping a good score on the next inspection will prove my abilities and earn some respect. I have had a lot of work to do.

My biggest fear is I will be blamed for poor results and/or not credited for improvement. Guess we will see! 

Good luck to you! I'm sure you've already done great job as far as I see, keep up!



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Posted 10 September 2021 - 07:16 PM

out of sheer curiosity, what is your plan if you have an allergen breach (punctured case or the like) perhaps thats what needs a bit of work, as your storage plan sounds good to me


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AltonBrownFanClub

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Posted 10 September 2021 - 08:03 PM

out of sheer curiosity, what is your plan if you have an allergen breach (punctured case or the like) perhaps thats what needs a bit of work, as your storage plan sounds good to me

Ooh good question. Maybe I have room for improvement there.

If it is a liquid, I have a large spill kit in the storage area that can absorb 4-5x of the largest cases.
None of the liquids are stored above anything they could drip on. They are stored on the bottom shelf or their own pallet.

 

Thinking about this now, I should verify that our floor cleaner is able to remove allergens. On Monday I will do a test spot. Put cones around an area, spill a small amount, use some of the absorbent, and mop afterwards. Follow up with an allergen swab and make sure it is effective.

If it is a solid, we would probably sweep/vacuum the debris and ensure it hasn't got on other cases. All of the packages are impermeable, so I am confident we would be able to remove it. The only exception is flour which comes in those dumb paper-esque bags. If anything got on those bags, I would suggest throwing it away. Flour is cheap and problems aren't.
 

I should be informed right away if there is a spill. My personal strategy is to err on the side of caution and throw away anything that was affected. We do not allow rework here.

Please let me know if you see any weaknesses in my plan. I've been doing so much policy work that it has started to become a blur. This forum is such a great resource, and I am so thankful for everyone's contributions.






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