5 replies to this topic

[nevin2756]

Could someone tell me do I need food fraud for each type of the product we purchased in Storage and Distribution Warehouse? 

We don't have any manufacturing and repacking process. Purchase all types of food product that are already packaged include frozen seafood, meat, noodles, spices, and can fruits etc. 

 

We do find co-manufacturers to put our company logo on the packaged product and I see we only did food fraud for these co-manufacturers product. Don't know if it is enough for BRC while someone said storage and distribution is exempt from FDA on the post below. 

 

In post#7 below said 21 CFR 121 Subpart A 121.5 (b) is exempt. 

Food Fraud VACCP from a 3PL standpoint - IFSQN

[AurW]

Hi, 

 

My company is BRC Storage & distribution and the auditing body required food fraud assessment on all the products within the scope..

It doesn't have to be very long though (mine is only 3 pages long and I have about 300 products) and it can be for groups of products, in you case you could class them by packaging type or storage conditions or generic description (e.g. cans, fish derived products, fruits derived products, etc.) the choice is yours as long as it is documented.

for each category you need to risk assess the risk of food fraud. by looking at what is done for each category, it should be easy to determine the likelihood & severity of each types of food fraud (substitution, dilution, counterfeiting, unapproved enhancements, concealment, mislabelling and grey market production/diversion) and therefore determine if you have products which could be at high risk of food fraud.

Hope this helps.

[SJ_LPCR]

 

Hi, 

 

My company is BRC Storage & distribution and the auditing body required food fraud assessment on all the products within the scope..

It doesn't have to be very long though (mine is only 3 pages long and I have about 300 products) and it can be for groups of products, in you case you could class them by packaging type or storage conditions or generic description (e.g. cans, fish derived products, fruits derived products, etc.) the choice is yours as long as it is documented.

for each category you need to risk assess the risk of food fraud. by looking at what is done for each category, it should be easy to determine the likelihood & severity of each types of food fraud (substitution, dilution, counterfeiting, unapproved enhancements, concealment, mislabelling and grey market production/diversion) and therefore determine if you have products which could be at high risk of food fraud.

Hope this helps.

 

 I also work at a storage and distribution facility and I am currently working on my risk assessments. I was doing something similar by doing the risk assessments by class them by packaging type or storage conditions or generic description.   , except I am doing individual assessment forms for each type. We are still a fairly new company and do not have many products right now, but we are growing quickly. I am tying to find an more efficient way of doing my risk assessments as I am worried that as we add products, having separate forms can get tedious. Could you please either explain how you do yours or share an example?

I appreciate any advice. 

Thanks in advance! 

[GMO]

I agree with all of the above.  Food fraud is normally considering your supplier base in any case so being in S&D vs a manufacturing plant might not have that different a study.  In fact, it might even be higher risk for a storage and distribution scope because you're not opening or processing anything so you're not likely to notice if something looks, smells, tastes different or has different testing results.  A lot of what you do has been subject to famous food fraud cases, so cheaper fish sold as more expensive, horse meat obviously, all the many many issues with spices. 

 

So you'd want some robust supplier quality assurance but also some testing if you can (and have the money) or sign up to one of the food fraud intelligence networks so you can be alerted and can grill your suppliers on emerging issues.

[Lynx42]

 

So you'd want some robust supplier quality assurance but also some testing if you can (and have the money) or sign up to one of the food fraud intelligence networks so you can be alerted and can grill your suppliers on emerging issues.

 

For a 3PL our "suppliers" are our customers who would heavily frown on us opening their packaging and testing it.  Especially as many things are proprietary and they still own the product.

We get product in and store it until our customers tell us where to send it.  Most of it stays on the same pallet it comes in on, and occasionally we will "pick" pallets by adding a variety of that customers products onto one pallet.  Most of our product is finished product that is ready for store shelves.  Some is raw ingredients that we store as overflow for certain customers or until they have a customer we can ship it to on their behalf.  We (most 3PL's) own zero product stored in our warehouses.

 

Cheaper fish and horse meat would not be something we could catch as we don't touch any actual product unless we are tossing it due to damage.  If we see exposed product, it is damaged, otherwise we can only go with what the label says.

 

FDA says we are exempt from a food fraud mitigation plan, but it's still in the BRC and SQF Storage and Distribution code so we are left weeding through everything that is designed for product before it's in it's final packaging.  It's a frustrating journey.

 

It's exhausting trying to take programs that are meant for certain specific functions (HACCP and SQF as a whole) and fit my little part of it into a plan that will get us certification and not kill my warehouse staff.  I've only been doing this for 7 months when our other warehouse (8 years at a hazmat facility) closed and I've made a lot of changes (my company is over 100 years old and we have people who have been with the company 40+ years) and I keep getting asked why on a lot of little seemingly crazy changes we've been implementing.  Does a storage and distribution facility with no exposed food REALLY need to sanitize their brooms and dustpans??? AND have different colors for allergens and glass (in a facility that hasn't had any glass breakage in years)??  You want me to count the windows and light bulbs? Can we really not tape something on our lift to hold pens and labels? Why can't I prop open this door and go talk to the driver?  I see the hole, but it's not actively leaking, so why can't it sit there until someone else sees it and decides to do something about it?  What, you want me to actually put this bag of leaking rice in another bag so it stops leaking???  Why haven't seen a rat in the building for 20 years!

[SJ_LPCR]

For a 3PL our "suppliers" are our customers who would heavily frown on us opening their packaging and testing it.  Especially as many things are proprietary and they still own the product.

We get product in and store it until our customers tell us where to send it.  Most of it stays on the same pallet it comes in on, and occasionally we will "pick" pallets by adding a variety of that customers products onto one pallet.  Most of our product is finished product that is ready for store shelves.  Some is raw ingredients that we store as overflow for certain customers or until they have a customer we can ship it to on their behalf.  We (most 3PL's) own zero product stored in our warehouses.

 

Cheaper fish and horse meat would not be something we could catch as we don't touch any actual product unless we are tossing it due to damage.  If we see exposed product, it is damaged, otherwise we can only go with what the label says.

 

FDA says we are exempt from a food fraud mitigation plan, but it's still in the BRC and SQF Storage and Distribution code so we are left weeding through everything that is designed for product before it's in it's final packaging.  It's a frustrating journey.

 

It's exhausting trying to take programs that are meant for certain specific functions (HACCP and SQF as a whole) and fit my little part of it into a plan that will get us certification and not kill my warehouse staff.  I've only been doing this for 7 months when our other warehouse (8 years at a hazmat facility) closed and I've made a lot of changes (my company is over 100 years old and we have people who have been with the company 40+ years) and I keep getting asked why on a lot of little seemingly crazy changes we've been implementing.  Does a storage and distribution facility with no exposed food REALLY need to sanitize their brooms and dustpans??? AND have different colors for allergens and glass (in a facility that hasn't had any glass breakage in years)??  You want me to count the windows and light bulbs? Can we really not tape something on our lift to hold pens and labels? Why can't I prop open this door and go talk to the driver?  I see the hole, but it's not actively leaking, so why can't it sit there until someone else sees it and decides to do something about it?  What, you want me to actually put this bag of leaking rice in another bag so it stops leaking???  Why haven't seen a rat in the building for 20 years!

I am also from a 3PL company that stores ambient temperature and dry food and feed items, and we are also SQF Certified.  Although our company is less than 5 years old, we have similar frustrations.  To address some of the push back we had all warehouse team members take food safety training. We also did a food safety culture training to ensure that everyone in the food safety mindset. I am not going to claim it is easy, but it is better to have everything in place than trying to explain why it isn't in place to an auditor.  

1. For cleaning equipment, we have separate brooms for inside and outside use, and they are stored separately and identified with labels. We also have a separate allergen clean up kit and glass clean up kit, both including their own labeled brooms and disposal bucket. Even if you have not had to use them, it is good to have them ready. "It is better to have them and not need them, than to need them and not have them."   
2. We did count all the knobs, lightbulbs, windows, and electronic devices used in the warehouse on our glass and hard plastics inventory list. We keep an inventory of all glass and hard plastic items. Once permanent items are counted, it rarely changes, but a major change to items stored in warehouse may change. As far as how frequently we update that information depends on what is being stored and the risk. We do have a glass clean-up process and a glass breakage report (again, it is better to have it and not need it...). Don't forget breakage of hard plastics should be handled the same as glass, i.e. a broken light-cover on the forklift.
3. Instead of propping doors open, we use badge access or allow our WO's keys to enter access door. We have a policy that if employees temporarily prop open a door for deliveries, the door must be monitored and closed immediately after use. This is to prevent unauthorized people and unwanted pest from entering the facility. 
4. As far as the rice bag, again based on risk. We will tape holes closed if that is all that is needed.  If the tear is not going to be controlled with tape, then another bag may be the answer.  It is all about controlling and eliminating the identified problem.
5. Food Fraud mitigation was one of our biggest struggles, as it was difficult to wrap our heads around how we could stop it when we do not open products or take samples. We added checks to our inspection sheets to look for evidence of tampering or issues with labels or descriptions. We did a mitigation plan based off risk possibilities...no matter how unlikely. 

This site is a great resource for information, although I agree that almost all the examples and training is focused on production of food and not warehousing. It still feels frustrating trying balance meeting all the food safety requirements and trying to keep our food safety program from being too complicated for our needs.