Posts Tagged “FSMA”

Three Key Takeaways of the Sanitary Transportation of Food Rule

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DSCN9011By 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:

  1. 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.
  2. 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.
  3. 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.

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Refrigerated Truckers to Face New Food Safety Rules

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DSCN7314Numerous new mandates for refrigerated carriers governing not only the condition and operation of equipment used transport foodstuffs but the capture and preservation of shipment temperatures, along with driver training requirements,  These are due to become effective March 31.

The Food Safety Modernization Act (FSMA) has new rules approved by Congress and signed into law by the president in 2011.

The mandate requires the FDA [the U.S. Food and Drug Administration] to be an enforcement agency in the food supply chain.  Violations of the mandate can lead to criminal prosecution.

While shippers and receivers are primary targets of the FSMA, refrigerated carriers become involved as the new rules require detailed temperature data to be collected and maintained, while imposing equipment and driving requirements as well.

There are three main broad areas where refrigerated truckers can be affected:

(1)   They would be required to develop and implement written procedures – subject to record keeping, probably for a 12 month time period – that describes how they provide temperature data;

(2)  Their practices for cleaning, sanitizing, and inspecting vehicles and transportation equipment;

(3)  and establish requirements for the training of carrier personnel engaged in transportation operations, including a requirement for records that document the training.

While the FDA  will not be telling shippers and carriers how to deliver foodstuffs, it will be in charge of establishing the framework for what’s required to deliver such goods and enforce those requirements.  Thus, the FDA now becomes an integrated part of the supply chain.  In effect, the FDA will become an enforcement agency – and one of their tools will be criminal prosecution.

Refrigerated fleets will feel specific impacts in several key areas of their operations:

  • It will affect trailer designs, depending on shipper requirements resulting from the new rules;
  • It will tighten sanitary cleaning requirements of said trailers;
  • There will be a “pre-cool” requirement for many shipments;
  • Temperature tracking will be mandated;
  • Data exchange and retention will be mandated;
  • Driver food safety training will be required and a record of that training must be kept on file for access upon request.

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