9 replies to this topic

[ganderson64]

Is it possible to store consumer packaged cheese above packaged meat products on warehouse racking if there is a solid barrier under the cheese products. We are a warehouse distribution environment. All meat and cheese arrives on our docks pre-packaged for delivery to the end user.

[kingstudruler1]

Since you used # Warehouse Best Practices, I dont think anyone would tell you its the best solution.   

 

I understand that there are most likely multiple levels of packaing for both products.   The risk is of contamination is very low in your situation.   

 

Is there a particular food safety standard you are using (SQF, BRCGS, etc)?

[ganderson64]

We are an SQF certified facility.

[SQFconsultant]

Is it possible - yes, this kind of sh*t happens everyday!

 

Is it advisable - NO.

[jfrey123]

Since you're speaking to a distribution scenario where nothing ever gets opened and everything is sealed, I agree the risk is low: for cross contamination to occur, only actual risk of cross contamination is if a forklift were to punch the cheese pallets open and then immediately punch into the meat and then send it to a customer. Even if that were to happen, simple checks for package integrity prior to shipment can address the issue.

That said, GFSI codes are written to cover so many facilities that they have to call for zero chance of violating a principal. Segregation of allergens is hard written into many schemes as an intended fool proof method to avoid allergen cross-contamination. But if you're strictly a distribution facility, you can write your program to address the potential hazards, and so long as there's evidence of you following your program, it should be fine.

Take SQF for example: in their code for Allergen Management for Distribution sites, they call out 2.8.1.1. It does not specifically state segregation as a requirement, only stating "[t]he allergen management controls shall be based on a risk assessment and include the identification, labeling, and handling of allergen-containing product, including product recoup, to prevent inadvertent cross contact." For that example, you need a risk assessment identifying how cross-contamination would occur, and how you prevent it. Part of that can include your hold program, placing packages on hold if they're damaged or seals are broken, and investigations to show no other products were contaminated by the unsealed.

Segregation is easier, but if you go through the steps to prove you've eliminated the chance of cross contamination, then proudly display your program to auditors and defend it when questioned.

[MDaleDDF]

I wouldn't, if for no other reason, to make your own life easier.   Jfrey says be ready to defend against an auditor, and I agree, abut in my experience, some auditors will write you up no matter what proof you show them.    I had it happen to me and had to appeal, etc.   I finally won, but it was a giant pita.....

[Lynx42]

This is what ours says, based on the finished goods storage standards from a customer that manufactures at an SQF facility, step 3 is almost a direct copy.  We are a 3PL dry storage only.  We will be having our initial SQF audit the end of May, so we will know then if it works.   Raw ingredients and single-layer package products containing allergens: 1.Stored separately from non-allergens to prevent cross-contact. 2.Physically separated in racks with like above like or non-allergens above allergen storage. a)Allergens stored in steel drums or hard plastic totes are exempted from the like over like storage requirements due to the low risk of cross contamination. i)Damaged allergens will be treated as a Foreign Material. ii)Any spillage/leakage of stored allergens will result in the inspection of all affected cases and the disposal of any non-conformance found. Like over like storage should be utilized where possible. Finished goods or ingredients with two or more primary layers. 3.Allergens that are finished goods that provide at least two primary “layers” (a bag or bottle in a box) of protection shall be excluded from the standard allergen storage criteria when stored for distribution. a)Stretch wrap on a pallet is not to be considered as a layer. b)Damaged allergens will be treated as a Foreign Material. c)Any spillage/leakage of stored allergens will result in an inspection of all affected cases and the disposal of any non-conformance found. Like over like storage should be utilized where possible.

[SQFconsultant]

Years ago I was in a DC doing an SQF Audit and while some of you may have thought I was a hard-ass when I was an Auditor there was a situation where we were walking around and I look up and there is a pallet of mixed nuts (completely sealed, overwrapped, etc) sited on top of a pallet of containers that contained soy flour (completely sealed, overwrapped, etc) and on the bottom was a pallet of beef jerky (again sealed and overwrapped)... the folks with me begin getting that racoon in the headlights look and I look at the QA Manager and simply said - you know it's 1pm now and I imagine we'll be back in the office around 3pm - so between now and then if somebody could come up with that written risk analysis about this (me pointing to the pallets in question) I might just take a look at that.

 

We completed the tour and headed back to the office and magically there was a risk analysis - beautiful in fact and I read it and I accepted it.

 

Since then however I've been present for about 5 or so Auditors doing inspections on my DC client facilities and 4 of them had this happen - I will admit I was hoping that at least some of them might do a pass in a similar manner - but none of them did and each one gig'ed the facility for it, all of these were argued with 2 go backs.

 

But, seriously why bother having to go thru that.

[MDaleDDF]

Glen nails it imho.   Why?   Ain't suppoosed ta.   So don do it..... lol.

[GMO]

In health and safety circles people often talk about the Swiss cheese effect (pun unintended). The layer upon layer of failures which happen before an accident.

Now, one control for allergens is not storing them above non allergens even in wrapped storage.

We have all been around the block enough for us to know that sometimes forklift drivers are clumsy and when they are, they almost always don’t fess up and admit their error. What’s more they seem to have a teenagers approach to cleaning, ie, I made a mess but someone else will clean it up.

So your fully wrapped pallets? Fine. But your fully wrapped pallets with a typical FLT driver? Not so fine and I bet you now that the error will be found just as the auditor does. I’m not saying that a damaged pallet would be good at any time but it damaged and spilled onto another pallet with allergen cross contact risk? That’s going to be at a higher level.

You can of course write a risk assessment and pray to the god of good driving but I’m a pragmatist. And an atheist.