Controls required if we lease/rent out part of our production facility

Looking for input from the many knowledgeable members here!

We are a small frozen stick novelty mfg. in So. California.

The owner is in the process of negotiating to lease/rent out a portion of our production floor space to a small company that will self produce produce ices in tubs, cups, and flavor concentrate gallons.  I have not had a chance to review the HACCP plan they currently operate under and they have never had a 3rd party audit.

My question is what I need to do to incorporate them into our HACCP and Food Defense.  My thinking is as long as we vet any personnel with access through background checks and I do a hazard analysis that documents their processes and how we will keep the 2 entities, ingredients, and products separate I should be covered for my any audits. Really want to get this right as we are inspected beyond our 3rd party by the State, Fed, and Army.

Thanks in advance for any guidance!

Hi John,

My first question would be how are you going to seperate/segregate the ingredients, packaging materials and equipment from the rest of facility?  More specifically, what WILL be shared between the leased area and the areas still utilized by your company?  

I would AT LEAST perform a comprehensive risk assessment of pretty much everything that the third party will be bringning into YOUR facility to ensure that there are no food safety or quality risks being introduced.  I would envision this as a third party audit (are you GFSI schemed...if so, you would be required to hold them to these standards if anything is shared as I have listed above).

Once you have a good idea of what this companies practices and capabilities are, I would seriously consider (based on the amount of segregation possible) the possibility of reviewing their training programs as well to ensure proper GMP's will be addressed and that employees are not walking into your areas without frocks/hairnets/beardnets/etc.  

If this company will be in a different building then that's fairly easy (I would just make sure that down the road when the lease ends that proper cleaning and environmental monitoring is performed to ensure cleanliness when you take the facilities back under your control).  If you are sharing the facilities and there is some co-mingling of products and process flow issues, I would REALLY take the time to consider all potential risks.  This could be HUGE!

Would what they do and what they use have an impact on your quality or food safety?  If no, and you can prove it, then I would say you should not incorporate them into your HACCP Plan.  If you do, then you are responsible for monitoring, auditing and correcting anything they do that affects you.

In other words, what controls would you put in your HACCP plan that shows you are controlling them?

Sorry for the delayed response...hectic past few days!  Thanks to those who have weighed in on my posting.