Distribution in Allergen Management

I work in a 3PL as quality manager. We have around 6 customers, with many different products. One of our largest is vitamins, and they recently informed me that one of their products must be considered an allergen, as it contains fish oil. They claim that all the requirements of not storing above non-allergens applies, but their orders are largely pick-and-pack, and thus require this product to be mixed onto pallets every day.

I cannot find much information on shipping allergens with non-allergens, but if they were to tell us we cannot store this product with non-allergens due to a contamination risk, shouldn't there be issues with mixing it onto the same pallet with 15 other non-allergens? Is there any consistency required there that states the product must be shipped on their own pallets?

For the record, there is such a small amount of fish in the product, and it's in sealed inners, that are in plastic, that are in a sealed case. The customer's quality team has tried to have it delisted as an allergen, as they have other product with omegas, but do not require an allergen tag. I just believe that if there must be storage requirements implemented on our facility, there should be shipping ones as well.

If anyone has any guidance, it would be much appreciated.

Only applies to bulk in storage not for staging to ship out,

You are correct in your thinking.  In your case and many others, the risk doesnt really change much.  However, the two processess (storage and shipping) have very different sets of standard practices for allergen segregation.  There is no "consistency" as you stated.  

We deal with the same thing as a 3PL.  All our customers that store finished product with us say that a finished product in at least 2 layers of packaging doesn't need to be stored as an allergen and have risk assessments to show that it's very low risk for contamination.  When we were discussing this, the cost of what to charge for dedicated space was brought up.  We never mentioned increased costs to customers as all show layer-in-layer finished product is fine to store how we want, although we do like above like when space is available.

We deal a lot with multiple allergens in a variety of combinations from one customer.  To sort through it all and separate like to like would nearly be impossible, but it's all a bottle or a bag, in a box, sometimes the box is wrapped in plastic or in a 2nd bigger box, on a pallet with a bottom sheet, wrapped in stretch wrap.  That stuff isn't going anywhere.  And if it does...  We have in our Allergen program that we will treat any allergen spills like a foreign object (namely glass) and will toss anything that is affected below it.   

Single layer packaging and raw ingredients we do keep segregated.  

Discuss the cost of dedicated space and see if they still insist.  It is frustrating when you are picking finished product allergens onto a the same pallet or when you go to the store and Wheat Chex boxes are touching the Rice Chex boxes with a huge "gluten free" logo on it, or the peanut and non-peanut M&M's are sitting all cozy on the shelf.

Our initial SQF GAP audit is at the end of the month.  I will know then if our plan works...

Amy

I'll stick with what I said and leave you all with a funny.

Years ago I did food safety inspects on Sam's Clubs on behalf of WM.

Besides walking around in and out of each department I'd hang out watching the trucks get unloaded and sometimes take Temps and use a stopwatch to see how long pallets of food sat in off load prior to being tracked to the various holding freezers and refrigerators.

WM required that their internal DC's separated allergens in storage.  --- but when it came time to stacking on the pallets that policy changed to lowest labor m, lowest cost - thus you'd have boxes of live lobsters dripping onto cabs of mixed nuts, next to 20 pound tubs of flounder and sides of beef on top of the chickens that was next to the cheese. Soft goods sometimes ended up on the bottom or on top.

Loads and loads were over stacked with blatant height violations in the trailers and then the pallets would sit in 90 degree heat during offload for over 30 minutes.

Their solution when the bad stuff would happen was to fire a junior manager  

After those lovely inspections I stopped buying anything that WM sold.