Allergen Control in Wholesale

Hi,

I wonder if someone can advise me concerning the allergen control at a wholesaler who is currently unaccredited. uncertified to any standard, and on filling in an SAQ that was sent to them,  they ticked that they don't currently have any allergen control because they don't open the packaging, food is purchased and stored but there is no repacking.

This has set off red lights flashing in my head and I've looked through the legislation and can't find anything that covers storage and distribution of goods only. Are they breaking the law by not having these controls in place or is there an exemption that covers this?

My main concern was the instance of food breakage (they have eggs on-site) or the chance that foods might be delivered in damaged packaging. Am I being too pedantic in insisting that they need a risk assessment at the very least?

Thank You!

Mmm..when I worked in grocery distribution, my allergen control program largely consisted of proper stocking of allergenic products. All of my allergens (flour, nuts, dairy, etc.) were on a list, and everything on that list was reviewed to determine if any special stocking requirements were needed.

When I got there, I was told "no they're all sealed, we don't open the boxes, it's fine." Ok..then why are these 50lb sacks of wheat flour stored over these sacks of coffee beans and the coffee beans are covered in wheat flour.

I didn't take it too far down the rabbit hole..I didn't make a list of EVERY item that 'contained' allergens. I focused on the actual allergens and reviewed or re-arranged in a few cases their stocking locations so that they couldn't affect non-allergenic products, all based on a quick risk matrix of those items.

You are not being too pedantic. I worked in Produce/Restaurant Specialty Ingredient distribution for a while, and we also did not open sealed containers. We still had a allergen risk assessment/ management program. 

Breakage and contamination from leaking packaging, as TimG mentioned are the biggest concerns. Flour bags are notoriously leaky and if they are stored in an upper level rack, they will contaminate EVERYTHING. We did daily inspections of our warehouse, to ensure that allergen containing products were only stored above like allergens, (Flour and eggs had their own designated locations segregated from other products) removed any leaking products as soon as possible and documented the clean up of even tiny allergen spills. I would not want to approve a supplier like this who doesn't think they need to consider allergen risks "because they are not opening any boxes."

If you own the product while it's stored in their warehouse you can request they come up with a program or you might want to look for another storage facility. 

We are a 3PL storage and distribution and SQF certified. We don't open any product because we don't own any of the product.  We also damage out anything that is exposed foods. 

Our policy is:

• Finished goods in 2 or more layer of packaging we don't segregate allergens (most customers don't even mark them as allergens and we'd have to open boxes to look at the primary packaging to even know what's in it). 
• Single layer packaged allergens is like above like or allergens on the floor.
• If an allergen leaks on a non-allergen that we would mark it as damaged and notify the customer for them to decide if it's shippable or tossed. 

We also have a risk assessment, but haven't yet had an auditor ask for it.

We have one customer who stores an allergen and a non-allergen with us and both ingredients go into all their products so they told us we didn't have to segregate anything (all product is in 50-lb paper bags), but we do anyway.  We have another customer who wants EVERYTHING kept separated and they pay extra for dedicated space, and mark all their ingredients and finished products with allergens.

This wholesaler, are they your responsibility?  I.e. are you buying things from them or temporarily storing things there?  If so, if they're unaccredited and you're GFSI I think you have bigger problems than the allergen policy and training.  How do you know their pest control is up to scratch?  Their traceability?  Their HACCP plan?

Hi Dee70,

Theoretically, risks are low... whether all planets are aligned, there are no broken cases or spillage from containers such as flour bags that almost always spill.

The risks appear when containers are compromised, either broken, damaged, etc.

Once, during an audit in the warehouse of the plant I was working at, the auditor observed a slight pollution from flour bags that were near containers of gelatin cases. As a consequence, we put partitions to prevent potential cross contact issues, to prevent the pollution to remain on top of other products when they were opened and carried over unexpectedly.

My recommendation, start by giving them the right to know of what allergens are, and their consequences. With that in mind, they could do a risk assessment and have a procedure in place in case of spillage. If they have riskier products as flour bags, they could place them in a separate area or take precautions to prevent cross contact issues. Important to note, dry cleaning might not be effective to remove allergens.

Hope it helps.