Packaging non-food grade item in food facility
Hello,
We recently got our SQF certification. We are an herb, spice and tea company. We also sell various accessories, one of which is a sage wand (non-food grade). We are currently buying it pre-packaged and reselling the wands, so the packages do not get opened in our facility and are stored and shipped from our finished goods building. There is a proposal in our company to buy the wands and repack them into our own bags in our facility.
How do we go about doing this, if we do? Can they be packaged in our same facility where we package food, but in a separate room? Or since they are non-food grade can they package them at our finished goods site (different building). I have concerns that the wands are sage and other herbs, which for our food grade items we consider salmonella to be a high risk and all items coming into our building need a negative salmonella result. These wands would have no testing, and also I would assume I should assess them for allergen risk......
Anyone have any advice on this or have dealt with anything similar? Or would doing this be not a good idea?
Thanks!
Hi,
I would definitely start with a risk assessment. If you can repackage the wands somewhere else on a different packaging line it would be best. There is always the possibility/risk of cross contamination if they use the same line.
Given the nature of sage wands I'd op for at min a risk assessment, but tend to want to go to a completely different room or different building on the property. Do file an exemption/exclusion with your CB.
If you *had* to have them repackaged at the same site, it would be best to have it done in a segregated area, like a separate room. Segregated storage area, too. And you'll want to make sure that if there are any contaminants present on the sage, that they cannot be transmitted via air/ventilation system, floor drains, moving equipment (pallet jacks, forklifts), etc.
Overall, I would encourage it to be done at the finished goods site. Likely much less risk to worry about.
I know of a sugar distribution place that once also stored food-contact packaging for other companies in their excess warehouse space. No issues, kept the packaging on the far end away from the sugar. Then they added some recoup/reprocessing machine in a "segregated" area. They must have forgot to include the ventilation system in their risk analysis or something, because fine sugar particles from the recoup machine got inside the air ducts and spread from that "segregated" area all the way to where the packaging was stored. Huge contamination incident. :oops2:
We package food and bath items in our SQF Facility. Risk Assessment, Cleaning Procedures, and supplier approval documentation are a must. If you have a possible environmental risk, can you ask your supplier to provide routine test results?
Alternatively, can you work with your supplier to have them package into your packaging (think Private Label)? This maintains the risk at the suppliers facility and allows you to market in your own packaging.
Segregate and have clean breaks between use. The non food product is effectively filth. Think of it no differently than any other incident that would introduce filth to your food production environment, like construction or renovations occurred.
You would need a very thorough set off sanitation procedures to provide some verification and validation that your two processes were separate.