By Robinson Fresh
Do you ship human food? What about perishable animal food? If so, the Sanitary Transportation of Food Rule, which is a part of the Food Safety Modernization Act (FSMA), will take effect on April 1 and impact many in our industry.
We have received a variety of questions around this ruling and what shippers and carriers need to do to prepare. In this blog post, Chris McLoughlin, risk manager at C.H. Robinson, and I will cover what you need to know.
Three key takeaways:
- Which products are subject to the rule? The rule applies to items that are shipped open to the air, temperature controlled for safety, or shipped in bulk trailers or tankers via truck or rail. The emphasis here is on food shipped for safety, not quality. Many people think produce is covered under the temperature controlled rule, but most produce is not—with a few exceptions, it’s more commonly only subject to the open container portion of the rule. This distinction is important, as the purpose is not to create undue burden or throw away product which is safe for human or animal consumption.
- When does the rule go into effect? There are different implementation dates for small and large carriers and small and large shippers. However, most shippers expect all carriers and transportation providers, regardless of size, to fully comply with the rule at the earliest date of April 2017.
- How does the Sanitary Transportation of Food rule connect to FSMA? The Sanitary Transportation of Food rule is only one rule of several under FSMA. Each of the rules stands on its own. The language, definitions, and applicability of each rule varies. You should take time to understand the scope of each rule. Especially if you’re in the produce world, you may find that your product is exempt from one rule, but included in another.
I want to reiterate that the Food and Drug Administration (FDA) has stated this rule is not intended to impose significant new requirements in the industry—in fact, the industry is already completing steps within the rule. The rule is simply a restatement or formal recognition of industry best practices and the requirement to document these processes.
Impact on Produce Shipping
When it comes to the produce world, it’s important to think about the role each company plays in the movement of goods under this rule. Are you the one calling the shots for how the product is delivered? (Often, the person or organization determining needs is a retailer or wholesaler.) If you are the one tendering the load, you are considered the “shipper” under this rule and are responsible for defining specific obligations.