4 replies to this topic

[clrmwebb4350]

Good day all,

I have a question regarding an overflow warehouse that we store food grade materials in.  We use the third party warehouse for temporary overflow. I did a risk assessment as required by SQF in 13.6.1.  They are not a food grade warehouse, but do not pose a food safety risk based on my audit. They are lacking pest control and light coverings. They do not store food or hazardous materials.

 

My question is concerning inspections. If we direct ship to the outside warehouse and do not conduct an inspection are we in compliance? The way I interpret the code is that outgoing shipments of food grade packaging (finished goods for us) need truck and product inspections. The code does not mention incoming material inspections.  Am I understanding this correctly?

 

We have an incoming and outgoing log for all loads. The materials directly sent to the OS warehouse will not be on the incoming log. The last few audits we have had, the auditor reviewed these logs. If I am missing an entry I do not want to get a non-conformance.

 

TIA for any input :-)

[SQFconsultant]

 

 

 

Did you tell the Auditor (who reviewed the logs) that you have suppliers ship to this Outside warehouse and then to you?

 

All cogs in the wheel need to be inspected.

 

I have a food contact packaging client that buys from 32 suppliers and they contract with five outside warehouses - all of which get inspected by their SQF Auditor

 

Not making things transparent will muck up the cogs in the wheel big time.

[Tony-C]

Hi clrmwebb4350,

 

I am a bit surprised that you have approved a warehouse that has no pest control arrangements?

 

I think you already know the answer to the question regarding inspections.

 

The relevant clause form SQF Food Safety Code: Manufacture of Food Packaging – Module 13 is 13.6.1.4:

Where raw and packaging materials, work-in-progress, and food sector packaging are held under temporary or overflow conditions that are not designed for the safe storage of those goods, a risk analysis shall be performed to ensure the integrity of those goods is maintained, they are not at risk of contamination, and there are no other food safety concerns.

 

So, there isn’t any mention of inspection. If an inspection isn’t required at the overflow warehouse and on arrival at your site my question would be why are you carrying out inspections? And why is the auditor checking your incoming log?

 

There are also food defense and material verification requirements, how are these covered for materials the arrive via the overflow warehouse?

 

Kind regards,

 

Tony

[jfrey123]

OP does state he's audited this site (or at least someone has, they could be ISO or other non-food related audit). 

 

Do you have a LoG from this warehouser, and does their LoG to you state they will never store hazardous materials?  I'm always down to try and be frisky, and I'd be brave enough to take on this challenge as 13.6.1.4 allows for non-food storage with a risk analysis.  So if you've concluded they're missing key components, how do you mitigate the risks?  A stronger trailer inspection can help for items coming from that warehouse.  Requiring tamperproof pallet wrapping can be a help.

 

Anyone of us who have had to use LTL shipping/receiving has had an auditor balk at it, and we've had to defend it.  This isn't all that different in my opinion.  You have ZERO control over who your LTL carrier stopped at prior to your delivery or after your pickup, so it becomes a matter of securing your pallets and product against the future risks.

[Scotty_SQF]

Agree with jfrey on this.  The only other thing I'd say if you are using this overflow warehouse is that you should have a contract with them and you are paying them.  So they should conform to some of the standards you set forth that you want them to have.  Before agreeing to utilize them, there should have been an initial inspection and assessment.  That way you could have pointed out your concerns and had them provide how they would mitigate them before agreeing to whatever terms.  They should at the very least have a pest control program.  That in itself makes me nervous.  I'd at the very least then ask them to provide inspections before they ship out for you or ship to you and provide documented proof of this inspection.  I would also increase inspection of their site say if you are only doing it annually, increase to quarterly at least.  I don't see a reason why an auditor would have an issue with anything you do to prove you have approved this warehouse as long as you are assessing the risk and mitigating which sounds like you are doing.

 

One site I worked at we had used an overflow warehouse company.  I did an annual inspection, had a documented report, documented risk assessment and this was all good for any auditor that came.