Hello Scampi,
Wow, you read my mind. I have been wondering about this exact requirement. When you compare 7.2 to v8 it is obviously new language they have put into the standard. I hope many more contribute to this thread because I would appreciate as many expert opinions as possible. For starters, i will share that my perspective is coming from a packaging facility, or you could say a "facility claiming zero allergens and therefore a very simple allergen control program". As I had mentioned previously in the forum, we have all witnessed the auditor go and look in the vending machine for candies and food with peanuts.. But why? we had plainly stated in our employee GMP document as well as signage in the break-room, that "no food can leave" the break-room and hands must be washed upon exit. But still, every audit the auditor looks in the machine. I always wondered "why does he just look in the vending machine and not ask about employee lunches?". I mean, if he/she is so interested in peanuts in the vending machine, then what would stop and employee from bringing a five pound jar of peanut butter to work and selling peanut butter sandwiches to everyone? In the face of GMP and proper signage, is the vending machine inspection done because of the nature of the peanut allergen? We see food products that must claim if they were made in a facility that has peanuts.
I guess what I am getting at is this, I interpreted this addition to SQF v8 as meaning as the following;
2.8.1.1---an assessment of of workplace related food allergens from locker rooms, vending machines, lunchrooms, visitors
1) is it possible a visitor/contractor could bring in an unapproved chemical? A chemical that is not on the "Chemical Registry"? Yes, it is possible and so we have added language to our visitor/contractor GMP document stating "no outside/unapproved chemicals". Likewise, employees are educated with the chemical control policy.
2) is it possible a visitor/contractor could bring in an allergen? Is this the importance of the 2.8.1.1? A request to add language to the visitor/contractor GMP sign-off document specifically stating "NO peanuts/tree nuts"? Is it a request to extend the control beyond the vending machine and put language into the employee GMP document exclusively forbidding peanuts? If you claim to be a facility that is totally free of said allergens, maybe that is exactly what they are asking for..
I have been thinking about this for months, and I look forward to the opinion of other professionals here at IFSQN.