17 replies to this topic

[Dee70]

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!

[TimG]

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.

[MaggieB]

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."

[Lynx42]

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.

[GMO]

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?

[aclizarraga]

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.

[Dee70]

Thank you everyone for your sterling advice - you've just confirmed for me what I suspected. I totally agree about the flour bags, and they are a bakery supplier so there are plenty of those .. but not only that, bags of whey also, which is a different allergen. 

 

We use them as a supplier because the business owner (who is 82) has a 20 year relationship with the supplier, and there's a provenance aspect to the products so they buy from him because he stocks raw materials from the locality. He was quite a small business for a long time but they have undergone some considerable growth in recent years and his systems I suspect have not grown with him. 

 

I absolutely agree with all of you, it's practically unheard of to have no allergen control in any kind of food outlet or processor, even those like him 'that don't open anything' . I have made an allergen matrix for him to start him off and he does stock an array of different allergens right across the board. He definitely needs to bring himself into the 21st Century.

 

Thanks again .. you're brilliant! 

Edited by Dee70, 24 June 2025 - 04:35 PM.

[GMO]

I think if you're using someone not in a GFSI scheme then you essentially have to do your own GFSI style audit (or pretty much) with them.  There's guidance in the standard as to what needs to be included.  Allergen control will be part of it.  But I'd also check far more.

 

What's their reluctance to go for GFSI?  Might be worth doing a really tough audit on them so they realise they're going to get an audit that they feel either way.

[TimG]

 

What's their reluctance to go for GFSI?  Might be worth doing a really tough audit on them so they realise they're going to get an audit that they feel either way.

 

If I was to walk out of this facility and start my own food manufacturing business, I would avoid going GFSI for as long as possible. The dog and pony show has been leaving a bad taste in my mouth as of late.

[GMO]

If I was to walk out of this facility and start my own food manufacturing business, I would avoid going GFSI for as long as possible. The dog and pony show has been leaving a bad taste in my mouth as of late.

 

We have some dark kitchens in the UK who are well off the radar of GFSI.  While it's not perfect at least it demands a certain level of system compliance.  In this example as well, as I pointed out, allergens aren't clearly controlled but what about HACCP, trace, pest management etc.  At least GFSI gives you some assurance they have a system.  Not that it's fully adhered to at all but without it, the law in the UK is far too weak.  Might be different elsewhere but with numbers of inspectors being relieved of their duties in the US, I'd want something more than just competent authority visits which are often weak and infrequent.

[aclizarraga]

Hello,

The International Food Protection Training Institute (IFPTI) is offering a virtual training course that might be helpful:

Allergen Awareness for Food Employees in Retail Grocery Settings. It takes 20 minutes plus an assessment.

This is the link where you could find more information:

https://www.ifpti.or...06-25T16:14:01Z

 

Hope it helps!
Best regards.

[Dee70]

Interestingly, after giving the supplier all of the information above, he was quite rude and kept repeating that they don't open anything therefore the chances of cross contamination was slim and that his EHO had never flagged up the storage of allergens as an issue. 

 

I've been looking amidst the legislation for something that says that allergen control is a legal requirement .. just to convince him that he is meant to have at least something .. but to no avail! 

[bkrjones]

I am not an expert on UK Food legal requirements, but I did find this resource from National Occupational Standards:

 

https://www.sqa.org....s/aq/J3PH04.pdf

 

"Performance Criteria

You Must be able to...

5. store food in accordance with organisational procedures to prevent cross-contamination.

In the glossary they define cross-contamination as 

"Cross-contamination: in a logistics environment there are two kinds of cross-contamination you need to guard against: the transfer of harmful bacteria between foods by direct contact (e.g. the juices of raw meat dripping on to cooked meat) or indirect contact (via the hands, clothing, cloths, equipment or other surfaces); and the cross-contamination of foods containing specific allergens (e.g. nuts, milk, eggs) with other food (the mixing of foods due to damaged packaging, spillage or via hands, clothing, cloths or other surfaces)"

[Dee70]

I'm actually quite shocked that this is not more clearly defined in the current allergen legislation. It covers manufacturing and foods packed for direct sale in some depth but as far as I can see, wholesale is somewhat ambiguous, and owners of these companies almost have a loop hole. Not all of them though, decent wholesalers are BRC accredited, and obtaining accreditation as you know is no easy feat .. and then you have these businesses on the bottom of the pile without even an allergen control document - pretty crazy really! 

[GMO]

If you're BRCGS accredited, you are within your rights (in fact, pretty much required) to ensure your supplier is either accredited or following similar practices and processes.  So you can go above what the legislation is and into best practice.  BRCGS standards are free to download so just get the storage & distribution one and insist they comply with that.  

 

There are training courses on allergens which are free on the FSA website but they only cover legislation which will only cover what not how.  So while a wholesaler could have, say, allergens stored above non allergens and that's not illegal per se, it is illegal for food to be contaminated with allergens it's not listed with so it makes sense to have storage practices which minimise that risk.  Etc. etc.

[aclizarraga]

What I see here is a supplier that does not care about the products they handle. They have the right to know, which I guess included why controlling allergens is important. They are in the “I know but I don’t want” meaning despite any regulation you could find, they will say “we don’t have issues so why should I care”. Unfortunately, there is not much to do here.
Allergen regulations focus mainly on the manufacturing side and not downstream. We have a similar problem with allergen management at primary production (i.e. grains like wheat, soy, oats, etc.) and the risk of cross-contact (adventitious allergens) that is not properly addressed in the regulations.

[jfrey123]

@Dee70, it really sounds like you're just stuck with some old school minded storage guys who don't want to deal with the reality of modern food safety.  Every reason they've given you actually is their allergen control program and should be written into an SOP as such with simple corrective actions:  "Our allergen control measures include keeping goods sealed in their original packaging.  Should a damaged package be discovered, the material is placed on hold with an investigation conducted to also place other affected packages on hold."  The fact they're tripling down on this with you would make me want to go visit their facility.  I'd bet a couple virtual non-real dollars that allergen control is not the only common GMP they're skipping...

 

More than a few times in my first job (a storage/processing 3PL spice toller), we had GFSI code items that didn't apply to us because we didn't do them.  But I learned we still needed an SOP to cover them.  Allergen handling was one of them, and it didn't apply because we didn't process allergens, but we still had to develop and SOP that basically said we currently do not handle allergens, but if we were to change that, this is what we would do.

[marco89634]

The true danger, which violates their legal food safety obligations, comes from breakages, leaks, and dust from damaged packaging (e.g., flour, eggs).

You don't need to ask for a complex system, but you must demand basic, pragmatic, and low-cost controls to demonstrate due diligence.

Require a one-page risk assessment, a written spillage procedure, and smart storage rules. The golden rule is to always store powdered or liquid allergens on the lowest shelves to prevent gravity-driven contamination.

To overcome their resistance, frame these controls as insurance for their business, not as bureaucracy, and provide them with templates.

If they still refuse, you must formally document the high, unmanaged risk in your supplier evaluation and let your management make the final decision."