Allergen storage and risk assessment

I'm doing an allergen risk assessment, and for the warehouse storage section, i want to document that there are allergens stored on racks in the warehouse in areas above forklift traffic. my concern is that there is risk in using these locations for allergen storage. they are usually big bags of ingredients with soy or almond or gluten, etc. oils and liquids are stored elsewhere. but i'm afraid if a bag breaks somehow, it would fall down and could be a cross-contamination risk. but I don't know how high that risk is for a bag breaking - except if there's a tear that no one sees and something knocks into the racks and it comes down or as a truck takes a pallet down, it could break. but would it matter that it's in a traffic area? it still needs to get cleaned up.

Is this valid or am i reaching? I work in a place that is not very open minded to new ideas and policies, and so i don't know if this is worth pushing to change these locations or if the risk is so low, i should let it go. i struggle to balance what i think to be good practice with also trying to keep the peace with other departments. I'm new in a facility of workers who've been here a long time or are related to the owners. it's.... a challenge for me and I'd like to have their support in these decisions. i don't have a co-worker with more experience to consult with. Thanks!

You would store like allergen over same allergen or under a non-allergen.

So, let's say you got apple powder in bags on the bottom of a 4-tier racking system, if you had soy over that, you would remove the apple powder and put it on the 2nd tier racking and put the soy powder on the bottom rack - thus you don't have an allergen over a non-allergen.

Or you would store up and down the same - all soy, all gluten, all etc on all the vertical (up and down) rack tiers.

You could store side by side and can also store by classification - for instance I've got almond flour on tier 1 bottom rack, and coconut flour right above and on the 3rd level straight up is walnut flour - all tree nuts by classification.

Years ago as an Auditor I was in a flavoring company walking around the storage area and witnessed broken bags of soy powder leaking into the almond flour below - that was also in a bag, but the bag was broken - it was actually much worse that day as they did not control allergens and thus the audit failed and the customer of theirs that I was doing the audit for suspended their agreement with them until they got their act together.

Allergens stored in sacks or any container that is easily damaged, cut, etc is a big problem - very high risk.

Having a good allergen clean up procedure is key and what you will do with that ripped bag or sack.  What was a process in a bakery that I was at was to pull the pallet down with the broken bag, clean up all the surrounding areas, and tape up the broken bag with a designated color.  The color chosen was a part of the training of non-conforming materials warehouse, sanitation, and production so that bag was not used in the process.  This allowed a good clean up without having to restack entire pallets for every broken bag (unless it was needed and determined by QA and sanitation).  As Glen stated the other component of having good over and under allergen storage practices is key as this reduces risk of cross contamination.  

Hi ewalsh224,

I agree with previous posts by Glenn and nwilson, allergen control in warehouse storage boils down to having a storage plan based on risk where non-allergens are less likely to be contaminated, e.g. above allergen containing products and then a spillage control procedure that is trained in and followed.

Also note that it is a good idea to ensure that materials are contained in robust packaging that helps prevent damage/spills and supplemented with pallet protection, for example corners & stretch wrap.

Kind regards,

Tony

We do have that scheme in the warehouse, with like-over-like allergens or under non-allergens.

my question is about allergens being stored in racks that are over a traffic area. we have racks that are constructed over forklift traffic, so they drive underneath them through the warehouse. do i treat the area below like a non-allergen? we wrap everything in plastic, or if we don't, i know that we can, so the allergens can be more protected. my worry is something leaking onto the floor and being tracked or onto a forklift. or is this risk the same as if it were stored correctly in the aisle?

OK, that's an easy one - NO, you can not store allergens over a traffic area.  

... i want to document that there are allergens stored on racks in the warehouse in areas above forklift traffic. my concern is that there is risk in using these locations for allergen storage. ...

Stairs and mezzanines often have a pan under them to capture debris, allowing traffic underneath to remain uncontaminated.  Does this storage space have an equivalent to this that would prevent leakages from contaminating the traffic under it?

If the answer is no, then you can't store allergens or anything else that poses a risk to the general population there.