Distribution controls

This article explains the distribution requirements following dispatch, so that the materials and product are protected from contamination and malicious contamination during delivery.

The standards

This article is written to meet the requirements for distribution controls in the following standards:

BRCGS Food Safety Issue 9 4.16.5 Product security
BRCGS Packaging Issue 6 5.10.1 Product security
5.10.2 Packaging
5.10.6 Contractors
BRCGS Agents & Brokers Issue 3 Not applicable.
BRCGS Storage & Distribution Issue 4 5.2.4 X Driver handling rules
5.4.2 – 5.4.6 X Temperature control
7.2.2 Load movement during transit
11.3.2 Cross-docking returns
12.4.1, 12.4.2 e-commerce returns
12.5.7, 12.5.8 e-commerce packing
FSSC22000 Version 5.1 FSSC22000 Version 5.1 2.5.9 Transport and delivery
ISO 22000:2018 8.2.4 g) transportation
IFS Food Version 7 4.15.5 Vehicles and equipment
4.15.6 Construction of loading/unloading area
SQF Edition 9 11.6.5.2, 11.6.5.3 Transport vehicles

The requirements

Product returns

A procedure must be in place for product returns, which must include a risk assessment that determines what materials can be returned and how they must be controlled.

The controls must establish how the returned material must be assessed, such as temperature checks or other forms of testing.

The materials must be placed on hold when they arrive at site, while the assessment is being completed.

The procedure must also state who is authorised to accept returns and what to do with rejected non-conforming materials.

Distribution controls when cross-docking

Cross-docking is where a material is transported via another location, where it needs to be processed to make the next journey.

For example, a pallet of product may be sent to location A. Offloaded at location A, and then processed to be put on another vehicle to make the journey to location B. The offloading and processing at location A is cross-docking.

Another example may be: Milk is picked up from farms by a number of small tankers. The small tankers then go to a hub and the milk is transferred onto a larger tanker, to be taken to another location. The transfer of the milk from the smaller tankers to the large tanker at the hub, is cross-docking.

There must be procedures in place which identify the controls for cross-docking to ensure that the material isn’t damaged or contaminated. When developing such procedures, you also need to validate the controls for temperature-controlled materials, including time delays. Make sure you also think about segregation controls that may be required when cross-docking materials.

If your business carries out cross-docking, you need to ensure that the roles and responsibilities for this process are well defined. This aspect is covered in the responsibilities section of the Management commitment, organisational structure and responsibilities article.

Driver procedures

Once the vehicle has been loaded, the driver needs to be trained to understand how to handle the load during transit to prevent damage and contamination.

Product security

Drivers need to know how to protect the security of the load during transit, particularly when vehicles are parked and unattended.

Load movement

Drivers should be aware of the risks of movement of the load, to prevent damage when the vehicle is being driven and how to secure it if needed.

Temperature

Where temperature-controlled materials are transported, the driver needs to be:

  • Provided with a system which alerts the driver when the temperature of the holding area goes out of the acceptable limits.
  • Trained in what to do, in the event of equipment failure.

When offloading multi-drops, the driver must be trained to ensure that the temperature of the holding area is maintained.

Return controls

Drivers need to be trained to understand:

  • What materials can be returned.
  • How to handle waste returns.
  • Any specific segregation controls.

Distribution controls when using a carrier

Where materials need to be delivered by carriers (courier, or postal service), you don’t have as much control on how the delivery is handled. This means that you need to protect the materials from additional risks from this type of delivery method.

Please note carriers can also be known as final-mile deliveries.

Terms and conditions

Terms and conditions must be in place and must be taken into consideration, when you’re working out what risks using the carrier may pose.

Product protection

A risk assessment must be used to work out what risks the carrier may pose, which may result in taint, damage or contamination (including malicious). Where a risk is identified, packaging controls must be put in place to mitigate this risk.

Packing of food products

When sending food product by a carrier, a packing specification must be used to ensure that:

  • Temperature control is maintained.
  • Consumer labelling is compliant and storage and preparation instructions are provided.
  • Traceability is maintained.
  • Staff understand what to do, if the dispatch of product is delayed.
  • Necessary checks to be carried out, by who and the frequency.
  • How to look for damages and the rejection criteria.

Packaging re-use controls

The BRCGS Storage & Distribution Standard now has a module for e-commerce. This module states how materials should be packed to protect them and then states, that if that packaging is to be re-used – there must be a risk assessment to control any risk that this practice poses.

We’re unsure how you can re-use packaging which is used for e-commerce purposes, but if you do – then you need to complete a risk assessment for this.

BRCGS Food Safety Issue 9

There are no significant changes to the clause that is covered in this article.

More information is available on the changes in BRCGS Food Safety Issue 9.

Questions

In this section, we share with you the questions that we’ve been asked and the answers.

Is legal labelling applicable to bulk deliveries? (17/07/23)

Question:

Does this [legal labelling] applies to road tankers conveying oil to our client? What information should be displayed regarding Migration Data? Sometimes, Serving Suggestions and Certifications are posted?

Answer

The rules for bulk transportation of materials are different. Legal labelling only applies to products which are sold directly to the consumer.

Migration data is still important but is applied differently. The container (tanker) must be suitable for food and therefore you must have the certification document for it – that proves that it’s suitable for food contact.

Want to implement distribution controls into your QMS?

This article is a topic within the subject of intake, storage and distribution. If you’d like compliant documentation for your management system on this subject, we recommend you purchase our pack.

Intake, storage and distribution

Pack 18: Intake, Storage & Distribution eDocs

This documentation pack provides you with everything you need to implement the goods-in, storage, stock control, positive release, vehicle management and dispatch section of your management system. The pack complies with all food-related BRCGS Standards, including Storage & Distribution. The pack includes a procedure which covers the controls required for intake of materials, handling of materials (putaway, picking and palletisation), storage, loading, vehicle standards, carriers, returns, transit and cross-docking.

Where needed, the controls have been determined by risk assessment, which you can review, adapt where needed and implement.

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