Sanitary Transportation of Human and Animal Food, FSMA Rule going into effect March 31. Previously just guidelines set forth by the FDA, it’s now law for those involved in the transportation of perishable to meet requirements in sanitation, temperature control and record keeping. Full text of the FDAs guidelines and who is covered can be found here: http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm383763.htm
I spoke with three cold chain logistics professionals who have a focus on food safety in transportation to help you prepare facilities, written agreements and transportation operations.
Jim Fox has more than 30 years experience in shipping and warehousing operations and is the founder of Verispect Smart Inspections™, a cloud-based documentation program to track shipping processes and protocols for compliance.
Edgar Vargas is the founder of Food Safety Now! A 3rd party fresh produce sampling operation as well as KleenTrans, an equipment and container sanitizing service that also offers training and assessment programs to food transportation and logistics professionals.
Dr. John Ryan has extensive international manufacturing quality and operations experience and is the President of Sanitary Cold Chain and author of the book “Guide to Food Safety and Quality During Transportation”. He is also managing partner with Edgar Vargas in TransCert, providing the cold chain industry worldwide with guidance, certification and audit services.
What do you foresee the biggest challenges will be for food transport pros with FSMA rule #7?
Jim Fox: “There are a lot of little companies out there servicing this industry. They are the least prepared and most adverse to what will be going on within the year with FSMA. The record keeping in any small business is naturally – let’s say – limited. Large companies already have it boiled into a system, they are used to process and paper controls. The little guys – not so much.”
Edgar Vargas: “What I hope to see, and I know it’s going to be a challenge, is a standardized, uniform Food Safety in Transportation program much like what auditing
firms such as Primus, LGMA, Global GAP or Harmonised look for. There is no such thing right now. The importing and exporting of temperature controlled perishables during transport is a need all countries share in common. The health and safety of humans and animals is the goal for everyone and sanitary transportation has been a big black hole in food safety.”
How will it impact operations for raw material suppliers? distributors? transportation and logistics providers/transportation brokers?
Jim Fox: “Most importantly the onus is on each step of the supply chain knowing and having written proof (documentation) of compliance by the previous holder of the commodity. If it does not have that documentation and proof of it, the receiver is holding the bag if there is an issue.”
Edgar Vargas : “Everyone is going to need to change their mindset and start thinking of sanitation on the surfaces of shipping containers the same way they think of food contact surfaces in processing and shipping surfaces. Everyone has to do his part to make sure that this chain is safe and everyone is in compliance”
When it comes to data and records retention of sanitation and inspection of containers, what do food transportation operations need to do to comply?
Dr. John Ryan: “As an example, temperature records must be delivered by the carrier to the shipper and receiver. Generally that calls for updating contracts of carriage to show agreement between them. Rules formalize the requirements and will cause written agreements. All washing, storage and precooling of containers with perishables is required. Maintenance stations (wash and temperature monitoring systems) must have written procedures and be able to document what was done in detail for each container washed.”
Jim Fox: “They need to get rid of forms on paper! 20% of it gets misplaced, they are prone to error and falsification. I know a 3PL here that had a facility in Connecticut. They had to find an inspection form for a customer and could not find it. The customer pulled all their product out of the warehouse.”
What are the training requirements and who needs it?
Jim Fox: “There should be a certification for drivers and warehousemen that includes basic inspection rules and why they need to be followed. It is very basic and these people already are in the habit, or should be, of inspecting things like forklifts, trailers and trucks. It is the same process, just different things.”
Edgar Vargas: “Anyone loading containers with perishables needs to be trained to inspect containers for damage that may cause temperature fluctuations or cause food to become contaminated or spoiled. Drivers carrying perishables are supposed to have food safety training as well.”
Shippers and carriers already have strict mandates and standards set by some of their customers, how is FSMA Rule #7 different?
Dr. John Ryan: “It may not impact them if they are in compliance with details of the law. When rolled into the preventive control rules, their customers must now be able to prove the shippers and carriers are qualified and certified and have valid preventive control systems in place.”
Edgar Vargas: “Requirements in the communication between the shippers/brokers and carriers about pre-cooling of containers, prior cargoes, and their next destination being included on the Contract of Carriage makes everyone comply, not just those working with the big retailers.”
What, if any, are the different container sanitation requirements for each industry, Fresh Produce, Seafood, Raw Meat, Dairy?
Dr. John Ryan: “Many – it depends on the industry. Dairy and bulk carriers are impacted differently since they must have cleaning and temperature data for three previous loads. Other industries only need to show cleaning and temperature records for one previous load”
Jim Fox: “They all are based on HACCP in one way or another. It all has to do with process steps, time and temperature and sanitation. The biggest hurdles I believe are the cross contamination issues that can occur in a vehicle or a storage location in a warehouse – like raw chicken stored on top of lettuce.”
Edgar Vargas: “There is no one-size-fits-all answer but in all cases water source testing and certification needs to be done- non-potable or recycled water will not be acceptable in sanitation procedures.”
What training will need to happen for inspecting containers?
John Ryan: “More than container inspectors are expected to be trained and to comply.
We provide certification and other training for internal audit teams and external auditors. All training must be documented and matched to the person actually doing the job.
Edgar Vargas “They are going to need to know what to look for and smell for in containers. Pathogens and bacteria are not visible to the naked eye. Physical damage to doors and seals of containers can affect temperature. It’s important that there’s consistent implementation by anyone loading containers and that any corrective action is documented. An untrained substitute or stand-in on the dock checking off boxes is not going to be acceptable.”
Is this rule going to force the retirement of some food carrying containers? Old reefers? Pallets? Bins?
Dr. John Ryan: “Maybe. While not specifically stated, FDA is now hitting those as part of preventive control rules – not clean = not preventive = FDA audit fail.”
Edgar Vargas: “It should. No one should be shipping fresh produce in containers with wooden floors or interior damage where pathogens could potentially enter cracks or holes in walls.”
Jim Fox “It could. It is all about maintenance of equipment. There is no reason in my mind that a trailer, properly maintained, shouldn’t be ok. Pallets on the other hand, you don’t know if people were shipping arsenic on them before you put lettuce on them.”
If you’re on the shipping side your next steps should be updating your food safety plan to document your protocols around temperature and avoiding cross contamination through sanitation of containers, pallets and loading equipment. Be sure you have a process in place for communicating temperature tracking, violations and pre-cooling requirements with carriers. Also, hire competent loading staff who can ensure compliance to the regulations.
Next steps for carriers include; phase out any reefers with wood interiors, train all drivers on the use of refrigeration units and loading procedures for temperature sensitive loads and implement a system to communicate with shippers for pre-cooling requirements as well as temperature violations and issues.