SQF - Necessity for HACCP Plans for Off-site Storage?

I'm currently participating in our annual SQF audit at a satellite facility that mainly performs repacking with occasional food-contact activities. This facility also maintains and staffs our off-site warehouse for all regional facilities which is approximately two blocks away. The auditor has taken a firm stance on issuing a non-conformance due to the fact that we have not created specific HACCP and/or Food Safety Plans tailored to storing finished product at said warehouse (i.e. transfer receipt, short term storage, and customer shipment). The product is shelf stable and stored in hermetically sealed containers; furthermore, each regional facility has created requisite HACCP / FSP for each product which includes the off-site warehouse as a part of the flow and analysis.

In my mind, there's no value in creating a new plan solely for this warehouse by simply copying the warehousing portions from the parent HACCP plans and pasting them into a new truncated plan. Does our method meet the code requirements, or is his concern justified?

Auditor is correct.

What I believe he is trying to have you do is take a look at the specific hazards associated with offsite storage. For example your current HACCP/food safety/Food Defense (I would think defense would be the biggest issue) plan probably has a section for storage, warehousing, outbound shipping. Well, these plans are all a bit like fingerprints, where you can only have a proper one if you focus on the specific hazards for what you're reviewing. 

If your current above programs only address onsite warehousing and shipping then you don't have complete program coverage because your plans are all set up to have coverage either to the truck (the case if customers arrange and pay for their own transportation) or to the customers door (the case if you arrange and pay for transportation). In those instances, the customer will have their own HACCP and FSP's that pick up appropriately where you left off. The onus is on THEM to do that either from the point their truck is loaded, or the point it arrives at their door.

I understand your thinking, I really do. The hazard is extremely minimal and is very much like what you currently do for other products that get shipped to customers and the warehouse probably follows all of your other facility warehousing requirements. I also think the auditor has a strong case though, because a gap in hazard analysis is still a gap. Whether there is almost no hazard associated with it or not, you still need to go through the steps and document it accurately to be sure there are no gaps in the chain.

I should have specified that all finished goods are loaded directly onto trailers and transferred to the off-site storage in what is essentially real-time; all of the plans include the transfer in the product's flow and risk assessment.

Having said that, I appreciate your explanation and agree that off-site storage should have it's own assessment to ensure it's thorough and representative.