5 replies to this topic

[jtopete]

Hi everyone,

 

We have a food grade storage warehouse that is registered with the FDA and is GMP certified with ASI (AIB competitor). We recently had a visit from the CA Department of Public Health and they asked to see our Processed Food Registration number. This was the first time I've heard about it. Is this a requirement even though we do not manufacture, repack, label, or process any food in our facility? It's a cross dock storage warehouse of nothing but store ready prepackaged food. I read on the website that storage facilities are required to have a PFR with the state but is there any way around this since we do not process, manufacture, repack, or label any of our stored goods? It literally comes in for storage and then ships right out the same way it came in. Thoughts or advice?

[seanpaulrader]

I assume you've read the "What processing activities are exempt from PFR?" subsection of their FAQ? Do you carry any of the listed FDB licenses? Are you holding "non-potentially hazardous, processed food" for less than 7 days? If the answer is no to those questions I don't believe you have any wiggle room.

 

I am surprised by this requirement as well. We must have flown under the radar at a previous employer, as this never came up.

Edited by seanpaulrader, 10 November 2021 - 09:13 PM.

[kfromNE]

If the state code says you have too, you probably won't be able to fight this. Do you fall under federal or state regulations. If federal, you may be exempt from state code.

[tahoeskier]

Any facility in CA that holds food is required to register.  You will most likely not get an on site inspection but you must get a PFR and pay the fee.

[TimG]

If the state code says you have too, you probably won't be able to fight this. Do you fall under federal or state regulations. If federal, you may be exempt from state code.

 

I've never found this to be the case. States can have ( I believe CA and NY, not sure who else) rules/codes above and beyond federal, and you are obligated to follow those in addition to the federal requirements. They won't trump the federal requirements, but are typically tighter in some areas then what federal is, never more lenient.

[kfromNE]

I've never found this to be the case. States can have ( I believe CA and NY, not sure who else) rules/codes above and beyond federal, and you are obligated to follow those in addition to the federal requirements. They won't trump the federal requirements, but are typically tighter in some areas then what federal is, never more lenient.

One example where this comes into play - specific requirements for retail vs food manufacturers.

 

Education requirement: requires each retail food establishment to have a person-in-charge, an owner, or manager of a food establishment be a Certified Food Manager (CFM) as outlined in the FDA Food Code by successfully passing an accredited ANSI food safety certification exam.

 

The above usually means servsafe or some similar certificate. In food manufacturing - HACCP or PCQI course.