Mixed Pallet - Raw Material

Hot debate with my team right now, maybe you all can add you expert opinions or factual information.

We kit spices, cheese, concentrates.. etc.

Often we will have partials leftover and put them only a single pallet, take them back to the warehouse on the same pallet and warehouse team will eventually put materials back to their locations.

I can have allergens.. organics.. conventionals mixed all on one pallet, non-permeable. 

My allergen validation allows for this.

The argument is : how long does it take for these items to go back to their home locations (allergens with allergens, organic with organics) ? And will an auditor hit us for having a mixed pallet? Regardless if it is completely sealed. 

We just had a similar thing with our predip area.   They did the same thing.   I now make them put items back daily that they don't use, and reenter them into the system, etc.   If not, it just gets sloppy, they forget, inventory gets off, etc.

As long as you can track it and that way if an auditor like me is walking thru you can show me the tracking and inventory details there would not be an issue. 

I think you can defend it strictly for transporting the partial raw materials back to the warehouse, kind of the same practice as the warehouse picker grabbing cases for a small production run.  When an auditor sees previously opened partials on a pallet, they're still going to ask questions like "Were those boxes open together on the pallet before being resealed?"  If they were open on the same pallet at any time, auditor is going to be able to make a case that it's unacceptable.

But then as soon as forklift driver sets that pallet in a home unattended, auditor is going to flip their lid over a comingled pallet placed into any storage type situation (even temporary).

Not sure which scheme you might be under, but SQF as an example has no leeway for this.  I've taken hits from auditors for them finding a completely sealed pallet of milk containing ingredients in pallet racking directly above a completely sealed pallet of soy ingredient.  

2.8.1.3 Provisions shall be made to clearly identify and segregate foods that contain allergens. Segregation procedures shall be implemented and continually monitored.

Some guidance found here:  SQFI | Allergen Management

a. Instructions for the receiving and operational staff on how to identify, store, and keep separate non-allergenic materials and any materials known to contain allergens shall be documented. SQF sites must identify all allergenic ingredients at receipt, and store them separately from non-allergenic materials, and from materials containing other types of allergens. Staff involved in receiving and storage must be fully aware of the presence and risk of allergens and the storage procedure. All ingredients must be clearly labeled with the name of the allergenic substance and must be stored and transported to avoid spillage or leakage onto other non-allergenic materials.

As long as you can track it and that way if an auditor like me is walking thru you can show me the tracking and inventory details there would not be an issue. 

Thanks Glenn, we do have a tracking system and can account for where product was distributed to down to the parcel. 

I think you can defend it strictly for transporting the partial raw materials back to the warehouse, kind of the same practice as the warehouse picker grabbing cases for a small production run.  When an auditor sees previously opened partials on a pallet, they're still going to ask questions like "Were those boxes open together on the pallet before being resealed?"  If they were open on the same pallet at any time, auditor is going to be able to make a case that it's unacceptable.

 

But then as soon as forklift driver sets that pallet in a home unattended, auditor is going to flip their lid over a comingled pallet placed into any storage type situation (even temporary).

 

Not sure which scheme you might be under, but SQF as an example has no leeway for this.  I've taken hits from auditors for them finding a completely sealed pallet of milk containing ingredients in pallet racking directly above a completely sealed pallet of soy ingredient.  

 

2.8.1.3 Provisions shall be made to clearly identify and segregate foods that contain allergens. Segregation procedures shall be implemented and continually monitored.

 

Some guidance found here:  SQFI | Allergen Management

a. Instructions for the receiving and operational staff on how to identify, store, and keep separate non-allergenic materials and any materials known to contain allergens shall be documented. SQF sites must identify all allergenic ingredients at receipt, and store them separately from non-allergenic materials, and from materials containing other types of allergens. Staff involved in receiving and storage must be fully aware of the presence and risk of allergens and the storage procedure. All ingredients must be clearly labeled with the name of the allergenic substance and must be stored and transported to avoid spillage or leakage onto other non-allergenic materials.

The raw materials are taken one by one - we have an allergen matrix to ensure we don't have any cross contamination. So one allergen is kitted off, before they move onto the next. 

One by one, each material moves to the pallet once its been sealed back up.

We follow SQF scheme.

I am wondering this  also because I have heard of auditors docking facilities for such a thing even when the materials are resealed completely. I just want to give the best guidance to my team.

It is always better to receive and store the allergenic material on separate and clearly identified pallets.

The raw materials are taken one by one - we have an allergen matrix to ensure we don't have any cross contamination. So one allergen is kitted off, before they move onto the next. 

One by one, each material moves to the pallet once its been sealed back up.

We follow SQF scheme.

I am wondering this  also because I have heard of auditors docking facilities for such a thing even when the materials are resealed completely. I just want to give the best guidance to my team.

Facilities I've consulted for have taken minors because sealed raw material allergens were stored above dissimilar other allergens in their pallet racking (floor position had a pallet containing soy, directly above on the rack had a pallet containing milk powder).  Auditor cited the potential for a forklift to puncture boxes on the pallet above and spill onto the pallet below, said we need to do better for segregation.  Another plant I visited received a minor for storing mixed allergen partials in their marked allergen area (those boxes too were sealed).

I'll repeat that I'd happily argue with an auditor about dissimilar allergens on a pallet when it's being transported back to storage.  But I'd write the program as such to disallow placing that pallet with mixed items in any sort of temporary or permanent storage.  

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We follow SQF scheme.

I am wondering this  also because I have heard of auditors docking facilities for such a thing even when the materials are resealed completely. I just want to give the best guidance to my team.

They aren't allowed to be stored that way by code, so they can't be transported that way either.

Transportation is certainly a riskier activity than sitting stationary on a rack.