9 replies to this topic

[MSPShawn]

I work at a SQF Facility that has recently had some damage to the outer wall of the facility and is in the process of expanding the facility.  Since we're in a situation with reduced storage space, upper management has been looking into outside storage to alleviate the compounded issues.

 

Upper management has connections with a nearby warehouse that has some empty space that offered the space for us for free, no contract, until they are able to get a contracted tenet to take the space we would be using.  We have to move the materials to the facility ourselves, and move the materials within the facility.  It would be no different than renting any other self-storage unit, just bigger.

 

We do not have a contract with them.  We do not have any certifications from them.  Outside of our facility, only the owner of the warehouse has access to the area for maintenance reasons.  I know this is not an ideal situation.  Upper management is resistant to asking the outside storage facility for certifications, since this is a free offer.

 

How would you handle this for your SQF program?  Contract Service Provider?  Co-packing?  Pretend we aren't using it?

[Setanta]

Is this a self storage unit, I got confused...

Is this facility adequate for storage of your product? Is it suitable for this use? What else is in that building?

 

Does it have pest control inside and outside? Are there allergens? Could YOU inspect that place? If it meets your requirements and would be acceptable under normal conditions, it should be acceptable. You would probably need to inspect it monthly, just like you would a place with no 3rd party audit.

[G M]

Generally a secondary location located "close enough" to the first can be counted as one site by the certifying body and covered by your own certification, if it is managed by one team.  It is up to your certifying body what is close enough to count as one site/audit, so the ones to ask would be your CB.  The CB is also supposed to be notified when a significant change to the facility or operation occurs, so this might be in order anyway by the sound of events.

 

With that in mind I'd be doing a regular sanitation operational inspection, glass/brittle, and monthly pest control inspection and any other basic basic inspections you do when one of your production facility storage areas is operating.  Treat it just like an on-site warehouse as much as possible. 

Edited by G M, Today, 06:41 PM.

[jfrey123]

How would you handle this for your SQF program?  Contract Service Provider?  Co-packing?  Pretend we aren't using it?

 

It needs to meet SQF requirements for storage as a contract service provider.  They're providing storage as a service, and while they don't need to be a GFSI facility, you need to inspect and make a write up regarding how all SQF code concerns will be addressed.  Allergens or hazardous chemicals stored on site?  Justifiable so long as they're kept completely separate from your product.  Pest control?  If not, you'll need hard inspections for any material coming in from them to look for rodent damage or infestation.  Building security?  Test it, have that owner prove no one else is getting near your product and storage it with tamper evident wrapping.  So on, so forth.  Given that there was damage to your building, you can make this part of your crisis management and document the off site storage was necessary to promote business continuity.  Go above and beyond, maybe even weekly inspections by you and your team to ensure all concerns you come up with are addressed.

 

At the end of the day, your food in that warehouse is at the same level of risk as an LTL carrier cross docking it at one of their hubs to transfer it between trailers.  Auditors can be convinced you're doing it as safely as possible given the realities of your situation.  Notify the CB, stress to them that it's temporary and you're taking active steps to ensure food safety during this crisis.

 

Your owners are going to push for that last option you suggested.  I've consulted with two companies in the past who tried this (against our recommendation):  one didn't get caught, the other had some explaining to do when an auditor asked to inspect inventory that was not on site.

[MSPShawn]

As a new user to this forum, just wanted to state I'm loving the interface and being able to seamlessly quote multiple responses!  Added numbers to the quotes for clarity of what I'm responding to.

 

1. Is this a self storage unit, I got confused...

2. Is this facility adequate for storage of your product? Is it suitable for this use? What else is in that building?

 

3. Does it have pest control inside and outside? Are there allergens? Could YOU inspect that place? If it meets your requirements and would be acceptable under normal conditions, it should be acceptable. You would probably need to inspect it monthly, just like you would a place with no 3rd party audit.

1. It is a nearby warehouse.  The self-storage comparison was an indication of the level of "service" they are providing, which is to say literally just the space.
2. I haven't been yet to personally inspect it, but the entire QA/Regulatory team is discussing inspecting the warehouse in the next week.  Our product is not microbial sensitive, and is shelf-stable at room temp.  We have ingredient stored outside, which has been approved under previous SQF audits.  (This is something else I'm working on, but its a heavily resisted fight as high as the owner of the company).  We don't know what else is in the building, but the space is sectioned off.
3. Unknown if it has pest control, but the area we're in has pest control laws for warehouses, so I would assume it does until I'm able to inspect it and see that it doesn't.  If it doesn't, we would at least set some traps on the inside.  None of our products have food allergens monitored by our country, or countries we sell to.  I would push for either weekly or monthly inspections by the QA/Regulatory team.

1. Generally a secondary location located "close enough" to the first can be counted as one site by the certifying body and covered by your own certification, if it is managed by one team.  It is up to your certifying body what is close enough to count as one site/audit, so the ones to ask would be your CB.  The CB is also supposed to be notified when a significant change to the facility or operation occurs, so this might be in order anyway by the sound of events.

 

2. With that in mind I'd be doing a regular sanitation operational inspection, glass/brittle, and monthly pest control inspection and any other basic basic inspections you do when one of your production facility storage areas is operating.  Treat it just like an on-site warehouse as much as possible. 

1. I believe it's less than 5 miles away, from what's been described to me, I think it's less than 1 mile away.  I will have to check with my boss if the CB was notified of the damage to the facility. 
2. Would you just add the location lists of the various inspections to the already existing list, or create separate documents for each of the inspections specific to the outside warehouse?  Would you mention the outside warehouse as a contract service provider or copacker that we're inspecting, or is it just "part of the facility"?

[MSPShawn]

It needs to meet SQF requirements for storage as a contract service provider.  They're providing storage as a service, and while they don't need to be a GFSI facility, you need to inspect and make a write up regarding how all SQF code concerns will be addressed.  Allergens or hazardous chemicals stored on site?  Justifiable so long as they're kept completely separate from your product.  Pest control?  If not, you'll need hard inspections for any material coming in from them to look for rodent damage or infestation.  Building security?  Test it, have that owner prove no one else is getting near your product and storage it with tamper evident wrapping.  So on, so forth.  Given that there was damage to your building, you can make this part of your crisis management and document the off site storage was necessary to promote business continuity.  Go above and beyond, maybe even weekly inspections by you and your team to ensure all concerns you come up with are addressed.

 

At the end of the day, your food in that warehouse is at the same level of risk as an LTL carrier cross docking it at one of their hubs to transfer it between trailers.  Auditors can be convinced you're doing it as safely as possible given the realities of your situation.  Notify the CB, stress to them that it's temporary and you're taking active steps to ensure food safety during this crisis.

 

Your owners are going to push for that last option you suggested.  I've consulted with two companies in the past who tried this (against our recommendation):  one didn't get caught, the other had some explaining to do when an auditor asked to inspect inventory that was not on site.

Would you still consider them as a Contract Service Provider if there's no contract?  My company is an older business and there's a lot of handshake deals made for things that gives me constant headaches.  Don't get me started on approved supplier lists...

 

I don't think we're going to be able to get any information on anything else stored on site, but it is a segregated area, so outside of liquids seeping through walls, I'm not sure the risk would be high.

 

As previously stated in my reply I was typing while you replied, I'm unaware of the current pest control on site, but the laws of the area require it for warehouses so I would assume it's there until we get to inspect and not see it.

 

Everything is pallet wrapped that would be going over there, so tampering would be evident.

 

There is no war in Ba Sing Se!  My previous job hid a bunch of stuff as well, and were quite adept at it.  I recognize some of the things in my current company and I would suspect they could BS there way out of it since this is a temporary situation.  This is part of what makes me want to get the certs to be an auditor, because I'm learning all the tricks.

[jfrey123]

I'd consider them a contract service provider, and hard line the bosses need something in writing.  That said, I know the struggle with the good ol' boys and their handshakes.  Of course this storage guy would never steal their merch and sell it to another company, but if he did, how would your bosses be able to prove it?

[SQFconsultant]

This is a NO GO in my book.

 

Find a facility that your company contracts with and complies the same or better standards than your SQF standards, etc.

 

A facility that is either SQF, one of the GFSI's or a strong 3rd party audit.

 

Since you will need to let your CB know that you have outside storage facility (because it will need to be included with your annual audit/inspection, you'll be looking at numerous issues if you go this handshake freebie route.

 

This is funny - pretend you aren't using it -- well, it will come out, it always does.  As an Auditor I had a bunch of those, even had a place using free space at one of those home-storage kind of places, that was an interesting day.

[MSPShawn]

Setanta, G M, and jfrey123,

 

Thank you all for your prompt replies.  They have been useful in confirming my stance and helping to clarify how to handle this issue.  I'm going to throw you for one more loop though...

 

Only a small portion of the products we produce are under the SQF Audit scope.  If none of the ingredients or finished goods that are within the SQF program are ever moved to that external warehouse, do we need to mention it during an audit?  I would still insist that we inspect it, since any ingredients stored there would eventually come back to the facility.

[SQFconsultant]

Would still be inspected to ensure that nothing within the scope or related to the scope is stored there - especially important since what is there in an outside facility is coming back into your primary facility.