26 INTERNAL STORAGE – Food and Drink – Good Manufacturing Practice, 7th Edition

26
INTERNAL STORAGE

Principle

Storage areas should be so designed that they are fit for purpose, and the layout and materials used allow for appropriate and effective cleaning. Storage procedures should be in place to prevent damage or deterioration of both premises and the materials contained therein. Effective storage procedures minimise the risk of contamination and are a key prerequisite within a good manufacturing practice (GMP) system. Raw materials, packaging materials, part‐processed and finished products, cleaning chemicals, personal items, equipment and machinery spares should be stored, where possible, in segregated, separate storage areas to minimise the risk of cross‐contamination.

General

26.1 Access to material and product storage areas should be restricted to personnel working in those areas and other authorised persons. Consideration should be given to site security and entry controls into designated storage areas. Designated separate lockers may need to be provided for both internal and external workwear as well as personal belongings that must not be taken into the production and storage areas (see 17.21f).

26.2 Packaging, food ingredients and products, equipment and other items should all be stored in separate, designated storage areas. Materials and products should be stored under the conditions specified in their respective specifications. Particular attention should be paid to the avoidance of allergenic or microbiological cross‐contamination and tainting. Where special conditions are required, they should be regularly checked for compliance with such conditions.

26.3 Materials and products should be stored in such a way that cleaning, the use of pest control materials without risk of contamination, inspection and sampling, retention of delivery identity or batch identity, and effective stock rotation can be easily carried out.

26.4 There should be effective protection of equipment spares, materials and products from contamination during storage.

26.5 Storage areas should be so designed as to minimise the risk of contamination of stored items. Effective cleaning of storage premises and equipment must be carried out at the designated frequency and using the methods and materials specified in documented cleaning schedules and instructions (see Chapter 21). The effectiveness of cleaning should be verified and as a result of such verification any appropriate action taken as necessary to address non‐compliance.

26.6 When developing storage procedures, the following should be taken into consideration:

  1. lighting, temperature and humidity control and ventilation should be adequate for the purpose. Storage areas should be designed and managed to minimise condensation, and any condensate pipes, for example from refrigeration units, should be designed to flow directly above a drain and not be allowed to drip onto the product, materials, packaging, equipment and personnel. This should be verified during premises audits. The condensate pipework should be designed to prevent airflow back into the pipework and consideration should be given to the need to sanitise the condensate produced. The pooling of water around storage areas, especially where there is vehicular access, should be minimised;
  2. storage areas should be kept clean and tidy to minimise harbourage or food sources for pests (see Chapter 22);
  3. damage to stored materials should be minimised and all spillages should be cleared away promptly;
  4. storage areas should have adequate proofing to prevent pest ingress and external doors should not be left open;
  5. all materials within storage areas should be protected from excess heat and light, water penetration and accumulation of foreign matter;
  6. stock rotation should be undertaken, and all items should be marked with their identification so that identification information is clearly visible during storage and traceability of all items is maintained;
  7. items stored on pallets should be neither touching the walls nor blocking the main doors or passageways. If racking is used, the layout should be designed so that the racking is far enough away from the wall to prevent pallets and palletised product being damaged or touching the wall. There should be designated vehicular and pedestrian access in storage areas with racking so that product can be safely inspected during storage. Space should be left in all gangways for product inspection to take place;
  8. any suspect stock should be segregated, ideally in an area designated for that purpose; and
  9. product should not be double stacked where this could prove a potential contamination risk or could affect the integrity of packaging.

Procedures should be developed on the basis of the points raised above, then implemented and verified to ensure that they are effective, understood and followed consistently by those staff working in storage areas. This is especially important in temperature‐controlled storage areas such as chilled or frozen stores and where allergens are stored on‐site. Furthermore, staff should be trained to understand the need to prevent material, packaging, equipment and product damage during storage and why the maintenance of product safety, integrity and product quality is important. Routine audits, or other appropriate verification activities, must be undertaken and recorded to demonstrate that damage of product and materials during storage is routinely assessed and minimised. Appropriate corrective action should be implemented as necessary in the event of non‐compliance and should be followed up to ensure that such actions are appropriate and remain effective.

26.7 The quality control manager or designate is responsible for developing and implementing appropriate monitoring procedures for temperature‐controlled storage areas to ensure that the storage area is capable of maintaining the appropriate temperature profile during work activities. The results of monitoring should be formally recorded and any appropriate corrective action taken where required (see Chapter 28).

26.8 Products that have been recalled or returned, and batches that have been rejected for reworking or recovery of materials or disposal, should be so marked and physically segregated, preferably in an entirely separate storage facility (see Chapter 29).

26.9 Material deliveries and product batches temporarily quarantined pending the results of testing should be so marked and suitably segregated, and effective organisational measures implemented to safeguard against unauthorised or accidental use of those materials or despatch of those products.

26.10 If a batch of finished product has to be temporarily stored unlabelled, to be labelled at a later date, the greatest possible care should be exercised in maintaining its exact identity and ensuring correct durability indication when the product is labelled (see Chapter 14).

26.11 Storage areas should be regularly inspected for cleanliness and good housekeeping, and for batches of products that have exceeded their shelf life or, in the case of date‐marked products, leave insufficient time for retail display. These inspections should be formally recorded, and the records should include in the event of non‐compliance any required corrective action and demonstrate that corrective action has been followed up to verify it has been effective.

26.12 Risk analysis should be undertaken by the quality control manager or designate to ensure that cross‐contamination, including where relevant airborne taint, is prevented. This is especially so at times of peak production where storage space may be limited. The Food Standards Agency (FSA) publication E. coli O157 – Control of cross‐contamination: Guidance for food business operators and enforcement authorities (2014) stresses the importance of managing storage not only of ingredients and finished products, but also of packaging. It also highlights the importance of ensuring that physical separation of materials is effective especially if high‐risk, ready‐to‐eat foods are manufactured/produced.

26.13 Pallet labelling should be undertaken so that it is clearly visible during storage. Attention should be paid to the effective adherence of pallet labels, especially in storage conditions that could affect the ability of the labels to remain intact on the pallet. The number of pallet tickets applied (and on which faces of the pallet) needs to consider the visibility of pallet tickets, especially when product is placed in racking. Consideration should also be given to maintaining traceability on pallets, especially of raw materials, when the outer wrapping is removed and/or where pallet tickets may have been adhered to boxes at the top of the pallet that will be used first. Traceability must be maintained at all times.

Storage of Chemicals, Lubricants and Oils

26.14 The stock controller or designate should be responsible for the taking into stock of all chemicals. She/he should also be responsible for ensuring that these items are as per the delivery instructions and are held, in storage, in their original packaging until required by particular personnel for cleaning or maintenance activities. All materials must be stored in sealable and labelled containers and handled and transported in a safe and responsible manner. Stores should be sound, secure, bunded (or alternatively the materials can be stored on bunded pallets), well ventilated, frost proof, have ease of access and have sufficient light to enable the operator to read the product label. Appropriate warning signs should be placed on access doors according to the inherent characteristics of the chemicals, for example flammable and corrosive. All materials should be stored off the floor, if not on shelving then on pallets. Shelving should be made from non‐absorbent material and powders should be stored on shelves above liquids. When materials are on shelves then the store must be bunded. Stores should be able to retain spillages, and emergency procedures should be in place to deal with accidental spillages. Protective clothing must be worn where applicable. Appropriate personal protective equipment (PPE) should be supplied for all operations involving chemicals, but it should not be stored in the storage area. PPE should be stored in a designated clean, dry, well‐ventilated and secure locker. The minimum requirements for PPE are detailed on the chemical product label. Any additional requirements should be identified during the Control of Substances Hazardous to Health (COSHH) assessment. Protective clothing must be personal to the individual, suitable for its intended purpose, in sound condition and the correct fit for the wearer. PPE should be cleaned, maintained, stored and disposed of according to manufacturer’s recommendations and statutory requirements. Empty containers must be stored as per legal requirements and must be suitably disposed of.

Product Integrity and Illicit Behaviour

26.15 The possibility of sabotage, vandalism, terrorism and other types of illicit behaviour (see Chapter 7) means that material, waste and product storage areas may prove vulnerable points for food crime. Access to material and product storage areas should be restricted to personnel working in those areas and other authorised persons. Consideration should be given to site security and entry controls into designated storage areas. Designated separate lockers may need to be provided for both internal and external workwear as well as personal belongings that must not be taken into the production and storage areas.