Co-Packaging in Separate Area

We are a Peanut Free facility, that is seeking to open up to options with other forms of revenue.

Specifically in packaging finished products for consuming - we would not manufacture these products, and some of them may contain peanuts, traces, or processed in a facility with peanuts.

We are KOSHER OU certified also

Can we do this in an area that is exempt from being apart of the SQF certified portion - as we do not want to jeopardize any of our certifications or relationships with our consumers.

All cleaning, equipment etc would be in the exempt area, and would never enter into the production facility or cleaning areas.

Please advise or send guidance, MUCH APPRECIATED!!

Short answer is no you cannot exempt this process from your audit scope.  SQF is facility specific and includes all processes within the facility.  We are going through a similar process of co-packing finished products and are documenting the entire process as we would be implementing/adding a HACCP plan.  You will need to put the work in and the due diligence to capture all risks and assess them appropriately.  

Even if the other allergens or products are processed in a separate room or building on the site that was previously exempt or not part of the scope of your previous audit, you will still need to take the presence of new hazards into consideration for your risk assessments and update many of your programs on the existing processes.

The certifying body isn't going to tell you that you can't do it.  It may, however, tell you that your current certification does not apply to this new product or process, and depending on what measures are taken to segregate the two processes may even invalidate your current certification.

You can do so in a completely different area/ different room and exempt those products from the scope of your certification, however that area/room is still subject to Auditor inspection.

Your facility will no longer be peanut free, not a claim you could make any longer.

On the other hand you could undertake this in a separate self-contained building on the same property - exempt it completely and be able to maintain your peanut free claim in the main building - still subject to inspection for drift over.

Personally, I'd go for the separate building - completely self contained so that you don't pollute your main facility - but don't exempt it, contact your CB tell tell them you want to add those products to your scope and of course revamp your entire SQF doc and process system. 

Could be possible, I've done similar under SQF.  I worked for a food sterilizer, small family run business that occupied a part of a warehouse suite.  The SQF certified food handling side made up about 1/3 of the total suite, separated by a walled partition with a chain link gate from a separate business owned by the same people that stored all sorts of random logistics items.  I'm talking pool chemicals, combustible stuff used to make fire starters, adult toys, kid toys, etc.  We drew up a map that laid out the entire suite, showing which portions were outside of scope, and all relevant SOP's made reference to never allowing comingling or transport of items from one business into the other.  We did have to use the same dock doors for both businesses, but our receiving/shipping SOP's forbid loading separate business trucks at the same time (and easy to enforce since we only had one forklift).  The auditors always inspected the opposing side for potential risks: pest control still applied to the doors, as did building security for our food defense, and so on.  We always had great chats about the types of merchandise stored there.  There was even food on occasion, usually ambient pre-packaged snacks like chips or whatnot, but none of it was ever related to the sterilization business.

I think the big key here was it being a totally separate business.  Additionally, I'm 100% positive we would've receive a critical failure if they ever found food product from the sterilizer stored there or obviously the general merch stored on our food side.  But our programs were solid, and it was a really easy business to run and keep separated.

To attempt it where you're describing, I would imagine needing totally separate staff for all production and sanitation work.  Your SOP's would need to heavily document the difference between the areas and processes.  Ideally it should be done under a separate business name as well to avoid the impression that you're trying to pass off the production under your SQF cert.  "Hey, we're SQF certified and also handle these things, wink wink" isn't a good look, and it'll be really easy for your clients to feel misled that you're SQF certified as they purchase these allergens from you.  The biggest and most important takeaway I had from your post is that you're a Peanut Free Facility:  Well, even if you partition it out and do a separate business name, you won't be a Peanut Free Facility anymore, and customers will feel misled when they show up in person and see the backroom operation.

Could be possible, I've done similar under SQF.  I worked for a food sterilizer, small family run business that occupied a part of a warehouse suite.  The SQF certified food handling side made up about 1/3 of the total suite, separated by a walled partition with a chain link gate from a separate business owned by the same people that stored all sorts of random logistics items.  I'm talking pool chemicals, combustible stuff used to make fire starters, adult toys, kid toys, etc.  We drew up a map that laid out the entire suite, showing which portions were outside of scope, and all relevant SOP's made reference to never allowing comingling or transport of items from one business into the other.  We did have to use the same dock doors for both businesses, but our receiving/shipping SOP's forbid loading separate business trucks at the same time (and easy to enforce since we only had one forklift).  The auditors always inspected the opposing side for potential risks: pest control still applied to the doors, as did building security for our food defense, and so on.  We always had great chats about the types of merchandise stored there.  There was even food on occasion, usually ambient pre-packaged snacks like chips or whatnot, but none of it was ever related to the sterilization business.

 

I think the big key here was it being a totally separate business.  Additionally, I'm 100% positive we would've receive a critical failure if they ever found food product from the sterilizer stored there or obviously the general merch stored on our food side.  But our programs were solid, and it was a really easy business to run and keep separated.

 

To attempt it where you're describing, I would imagine needing totally separate staff for all production and sanitation work.  Your SOP's would need to heavily document the difference between the areas and processes.  Ideally it should be done under a separate business name as well to avoid the impression that you're trying to pass off the production under your SQF cert.  "Hey, we're SQF certified and also handle these things, wink wink" isn't a good look, and it'll be really easy for your clients to feel misled that you're SQF certified as they purchase these allergens from you.  The biggest and most important takeaway I had from your post is that you're a Peanut Free Facility:  Well, even if you partition it out and do a separate business name, you won't be a Peanut Free Facility anymore, and customers will feel misled when they show up in person and see the backroom operation.

For this sitution we are not trying to pass it off as SQF certified, we are just looking to co-pack products for other companies in a seperate area.

I have had a facility (that currently still operates in this way) where we manufactured baked goods under the scope of SQF and, in a separate room, assembled products that were not part of the scope and considered retail. The auditor was free to review the GMP area and the staff was trained and held to the same standards as the SQF staff. In our case, there was a shared hallway and one door led to the SQF regulated area and the other to a general GMP area. We never had any issues with the auditor.