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Storing food ingredients in same warehouse as food contact packaging

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pattit

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Posted 13 May 2024 - 11:39 PM

My company recently got SQF certif. at one location for manufacture of direct food contact flexible packaging (100% score, proud to say).  Now I'm asked to do SQF for storage and distribution at a warehouse handling some direct food-contact packaging that we don't even produce.  I figure that's doable, esp. w/what was created for the manuf. site.  But the customer also wants us to store "ingredients", including "soybean oil, salt, rice, etc." (all that I know so far).  I have a concern that other customers of F/C materials that we store may not want their products in same warehouse with actual food.  Short of asking customers directly at this point, anyone have experience with this?  Allergens come to mind, but then I google and find while SOY is a huge allergen, refined soybean oil is not.  Where do we draw the line and what do we need to ask in advance?

 

I searched and hope I didn't overlook an existing thread on this, and if so, please just re-direct me...  Thank you!

 

 



Slab

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Posted 14 May 2024 - 12:39 AM

In the US food code, food contact packaging is an ingredient ("food" per sec 201(f)). Your risk assessment, GMPs, and PCs for storage and distribution would be the same.


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pattit

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Posted 14 May 2024 - 12:51 AM

Thank you.  I have to collect a ton of info for every raw material used in our manufacturing (films, inks, coatings, adhesives...).  But for storage and distribution, do I have to have that on hand with EVERY ITEM in our warehouser (we literally even sell janitorial supplies besides things like strapping and tape).  Do I need an allergen letter for toilet paper?  And my main post was to ask if any customers considered NOT storing F/C packaging at a warehouse that also stored ingredients.  Does anyone have experience with this?  Thank you.



Lynx42

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Posted 14 May 2024 - 02:03 PM

We are a 3 PL and at our main facility has food, food contact packaging (plastic bottles, paper and plastic bags), motorcycles (boxed with no fluids), appliances, some non-food powdery grit (I think for sandblasting or to put on sandpaper or something) and it's all in it's own place.  We have racking on one side that is mostly food, and most of the non-food stuff is on the other side of the warehouse with a few aisles of food.  Anything that will directly touch food is considered "food" in our facilities, and the food packaging we store is treated the same if there was food inside. We store everything by customer so the only mix of food/non-food is when customers have both stored with us.  We have a beer company that also stores mugs, glasses, paper coasters and such with us which are all in the same aisle together.

 

You don't need an allergen for toilet paper... We have a list of allergens stored in our facility and a map of of what allergens are in which aisles as a companion to our allergen program.  Most of our food is finished products so there are a mix of allergens in things like bottled sauces, but we do have some raw ingredients we store.  We don't use it, just store it until our customer tells us where to ship it.

 

Our HACCP plans has no CCP's, so we just have one since everything follows the same path and I lumped everything all together:  This is for another facility that will be SQF before our main facility.  Our customer (who is SQF) told us the food contact packaging was "ingredients" and told us to list it this way.  I originally had "food contact packaging" under product description.  

 

Product Description:

Retail Prepackaged/Prelabeled Finished Goods, Retail Aseptic Sealed cans, Raw Ingredients.

Product types are Syrups, Batters, Breading, Dry Ingredients.

 

Allergens:

Wheat, Soy, Milk, Egg, Sesame, Tree nuts, Shellfish, Fish.

Canadian allergens: Sulphites,

 

Packaging Used:

Plastic bottles, glass bottles, cans, plastic buckets/pails, paper bags, plastic bags, carboard and corrugated cardboard cartons, supersacks.

 

Storage requirements:

Bulk and rack storage in ambient warehouse.

 

Intended Use:

Retail food establishments, general public, food manufacturers

 

 

Amy



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pattit

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Posted 14 May 2024 - 02:21 PM

Thank you so much, Lynx42.  This is exactly the info. I needed.  My concerns were heavy on driving other customers away and you have alleviated that concern.  I much appreciate your experience and the wisdom given.  Thanks.


Edited by pattit, 14 May 2024 - 02:21 PM.


Lynx42

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Posted 14 May 2024 - 02:39 PM

Thank you so much, Lynx42.  This is exactly the info. I needed.  My concerns were heavy on driving other customers away and you have alleviated that concern.  I much appreciate your experience and the wisdom given.  Thanks.

 

No promises on the "experience and wisdom" part...  I've only been doing this for 7 months when our facility with hazmat moved out of state.  Our GAP audit is in 3 weeks, so hopefully our customer didn't steer me wrong on the bits and pieces of help they provided.

I've learned a ton and have been on this site almost daily looking up things and asking questions.  It's been a godsend, but I can't always find what I'm looking for.
Being a 3PL storage and distribution is both easier (no CCP's and such), but also harder to find examples on how to do things because everything is geared towards actual processing and manufacturing. You can easily find info on what to do for raw materials and ingredients, but finished product in several layers of packaging is something else. I'm currently working on food fraud, which if I'm reading the FDA guidelines right I'm exempt from, but it's still in the SQF Storage and Distribution code so hear I am again, trying to weed through to something that makes sense.

 

Amy





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