New In-Transit Temperature Monitoring Rules

New In-Transit Temperature Monitoring Rules

DSCN7352By Cargo Data

The Food and Drug Administration has released final rules for “Sanitary Transportation” of food products that will be used for human and animal food.

This paper highlights passages from the FSMA text which shippers, carriers, and receivers will need to study as they formulate their SOPs, specifically with regard to in-transit temperature monitoring procedures when transporting perishable food products covered by the Sanitary Transportation subsections. The focus here is on the movement between the shipping point of the finished product to the distribution center or point of sale.
Primary responsibility for determining appropriate transportation operations now rests with the shipper, who may rely on contractual agreements to assign some of these responsibilities to other parties.   Shippers must develop and implement written procedures to ensure that equipment and vehicles are in appropriate sanitary condition.   Shippers of food transported in bulk must develop and implement written procedures to ensure that a previous cargo does not make food unsafe.

And shippers of food that require temperature control for safety must also develop and implement written procedures to ensure that food is transported under adequate temperature control.  If a covered person or company at any point in the transportation chain becomes aware of a possible failure of temperature control or any other condition that may render a food unsafe, that food must not be sold or distributed until a determination of safety is made.

The shipper and carrier can agree to a temperature monitoring mechanism for foods that require temperature control for safety.

The original proposal specified that a compartment must be equipped with a thermometer, temperature measuring device, or temperature recording device.  The agency agreed with commenters that there are a number of effective ways for ensuring temperature control that parties subject to this rule should be able to use.  The agency also agreed with commenters that carriers need to demonstrate they maintained requested temperature conditions only upon request, rather than as a requirement for every shipment, as previously proposed.

Key Take-Aways:
1. The Shipper (or shipper’s representative) now assumes formal responsibility to ensure the conveyance (trailer, truck, container, etc.) meets the suitability requirements for the Sanitary Transportation of food products as defined by the Act.
2. These guidelines also expressly promote necessary cooperation between the Shipper, Carrier, and Receiver (customer) to ensure and confirm effective temperature control throughout the loading, transportation, and receiving/acceptance of subject perishable food products.
3. Expensive “real-time” temperature monitoring technology is NOT required.
4. Electronic temperature monitoring and/or recording devices are acceptable.
5. Carrier must provide, upon request, proof that requested temperature conditions were maintained during transit.

Cargo Data Corporation recommends shippers, carriers, and receivers each study the FSMA text to determine their responsibilities as mandated by the Act.  Clearly, accurate temperature records, ease of use, cost effectiveness, transparency, and easy data archiving features will be important aspects of any in-transit temperature monitoring program.
Cargo Data’s Lightning NFC temperature monitoring system is designed specifically to be a Turn-Key system to meet the needs of most shippers, carriers, and Receivers to achieve FSMA compliance for in-transit temperature monitoring.

Visit the website (LightningNFC.com) to view a brief video presentation highlighting Lightning NFC operations, features, and benefits.
For the Shipper:

Lightning NFC instruments are easy to activate and place. Shipping clerk simply notes (or scans) the instrument serial number for inclusion in shipping documents, order passing, and BOL.  Cargo Data also recommends the shipping clerk write the shipment’s PO number and other shipping details on the instrument label as a backup in the event the instrument becomes separated from its intended shipment.
For the Carrier:

No action is required by carrier beyond confirmation that Lightning NFC instrument has been placed in the shipment and the instrument’s serial number is listed on shipment BOL/Manifest.
For the Receiver:

Lightning NFC temperature monitoring instruments are provided in a high-visibility moisture resistant pouch which simplifies locating the instrument within the shipment.  Lightning NFC is also available with a free optional locating beeper which sounds intermittently to provide location assistance (not recommended for export shipments).
Lightning NFC instruments use NFC wireless technology to transfer all temperature data to a smart phone or tablet.  The Receiver/Inspector can instantly view the temperature data, make arrival quality notes, document internal (pulp) temperature, and even add photographs of the shipment to the temperature record. All temperature data, notes, and photos are automatically sent to Cargo Data’s UpLink cloud server for permanent archiving.
UpLink Online Temperature Data Review:

Shippers, Carriers, and Receivers can view the shipment’s temperature data online as soon as the Receiver transfers data from the instrument to the smartphone or tablet. Simply navigate to LightningNFC.com or cargodatacorp.com and enter the instrument serial number into the UpLink data retrieval field on the homepage. A free and fully detailed temperature report is available for viewing, printing, and/or downloading.
Cargo Data Corporation’s Lightning NFC temperature monitoring program is a simple turn-key program which brings easy FSMA in-transit temperature monitoring compliance for shippers, carriers, and receivers. Contact Cargo Data Corporation at 800-338-8134 or information@cargodatacorp.com for more information.