Off site distribution considerations (SQF)

Hello, we are SQF certified. We are currently in contract negotiations with a very large customer for nation wide sales.  Everything is moving forward but I had a question about storage and distribution.

Currently we release ownership with our product at our loading dock doors when it is loaded onto a truck.  With this new customer they want to send our products to a 3^rd party storage and distribution center.

We would retain ownership of the product until it is sorted and loaded onto a truck leaving that center.

What would I need to do to stay within compliance?

Do I need to do anything since they are a contracted company?

I am assuming many other types of products are held at this facility.  Do I need to address this in HACCP plans, Food safety plans, risk assessment, Food defense plans etc?

Does this affect my product flow?

I have been researching but I am only coming up with partial answers.  I want to make sure that we remain in full compliance with FDA and future audits etc. I would greatly appreciated any guidance you could give me. Thank you so much for your time

With this new customer they want to send our products to a 3^rd party storage and distribution center.  We would retain ownership of the product until it is sorted and loaded onto a truck leaving that center.  What would I need to do to stay within compliance?  Do I need to do anything since they are a contracted company?  I am assuming many other types of products are held at this facility.  Do I need to address this in HACCP plans, Food safety plans, risk assessment, Food defense plans etc?  does this affect my product flow?  I have been researching but I am only coming up with partial answers.  I want to make sure that we remain in full compliance with FDA and future audits etc.

 

I would greatly appreciated any guidance you could give me.

 

Thank you so much for your time

 

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can you get the customer to contract the middleman directly, if so your responsibility stops like it always has before as the middleman represents the client.?

I found out this morning that We would hold the contract.  I got an answer back from our certifying body and she replied with -

"Since you are retaining ownership, you are retaining food safety responsibility.  If there are food safety risks that need to be controlled, and the warehouse is managing them for you, then the FDA will be concerned about how you do this.

As far as SQF is concerned, you need to include the warehouse in your contracted services program and  be able to demonstrate how you are specifying and ensuring that the food safety controls are identified and met.  These days most warehouses are being required to be GFSI certified so that would assist you in your controls."

what do i need to change to do this?

OK, so you place them on your contracted service provider list and require they provide you with their FSMS/HACCP program, procedures, etc. I would suggest conducting your own audit on their facility or ask them to provide the most recent one - I default most times to do-it-yourself however.  You will also need to run a food fraud assessment, risk assessment, etc.

OK, so you place them on your contracted service provider list and require they provide you with their FSMS/HACCP program, procedures, etc. I would suggest conducting your own audit on their facility or ask them to provide the most recent one - I default most times to do-it-yourself however.  You will also need to run a food fraud assessment, risk assessment, etc.

Thank you.  Im not sure my boss will let me fly out to see it. 

We are shipping frozen products, would i need to get copies of their temp logs? 

Do I need to establish something to monitor trucking temps.  This is all new to us.

Should i run risk assessments based on their latest certification reports?

Sorry to ask so many questions but I run this part of the company by myself.

 There are 2 different issues here: FDA and SQF.

FDA regulations apply to each registered facility and the foods they handle. FSMA does not make distinctions for who owns the product. Your HACCP / Food Safety Plan applies for as long as you have control over the product. When it moves to another facility - their plan applies. That may over-simplify a bit since you are still to address consumer use in your plan. Still - your obligation is to have a clear understanding of the potential hazards and to control them to the best of your ability by doing it yourself or by having contracts that require it to be done. SQF is supposed to be based on risk and if there is low risk, certification and audit reports from the storage locations may suffice. Be sure you have documented a risk assessment defining your choices. Be aware that the FSMA Sanitary Transportation Rule also applies since your product requires temperature control. That rule helps define what should be in contracts, who is responsible for sanitation and what records are kept by whom for temperature controls for that piece of the food chain.