There’s no need to cry over spilled milk. But melted ice cream? That’s another story.
One of the central ideas behind FSMA was to try to cover as much of the food supply chain as possible. From the Produce Safety Rule, to both Preventive Control rules and the rules regarding foreign suppliers, the regulation puts controls into many nodes in the chain.
But what good is it all if the way everything from raw ingredients to finished products are transported isn’t safe as well? Enter the Sanitary Transportation Rule, which covers road and rail transportation within the U.S. (If a foreign product is not intended for U.S. consumption or only travels through it from one country to another, it isn’t regulated under this rule.)
“FSMA really hit the manufacturers hard, and they put a lot of systems within the plant,” said Brian Hammer, senior transportation consultant at Nationwide Insurance, who deals with carrier drivers. “There was a good realization that, ‘Hey, we can do everything right here within our four walls, but all of the sudden it’s going to go in the four walls of a trailer down the highway, and there are a lot of things that could happen to that food in route.’ ”
Key requirements of the rule include design and maintenance of vehicles used to ship food and measures taken during transportation such as temperature controls and preventing contamination between products. Training in these areas and records of procedures and agreements are included as well.
Hammer gives us insight on some of the rule’s ins and outs, and how everyone can help each other stay compliant.
QA: It seems like this rule is really about making sure there’s good written and verbal communication between shippers, loaders, carriers, receivers and brokers. What tips can help make sure this communication happens?
BH: The shipper should provide the requirements so the carrier can follow a checklist of everything that carrier needs to do. But there is certainly a big issue with the communication between shippers and drivers. There’s always communication between the shippers and the carrier. But sometimes it’s lacking when that driver shows up to the facility. One of the things I think happens most is that requirements may have been communicated to the carrier, but a lot of that information is best given to the driver. The carrier has an obligation to make sure their driver knows the requirements, but if you can’t help educate the driver while he’s there, that’s an issue.
QA: Did the COVID-19 pandemic throw a wrench in that by limiting in-person communication?
BH: If you talk to drivers, there’s a real concern there that shippers don’t talk to anybody in the truck anymore. First of all, drivers want to make sure it’s properly loaded. Because some of the issues with food safety could be that the freight bangs against itself, and it opens up a container — now that food is exposed. Load security used to be a driver’s responsibility. But now drivers aren’t allowed back there, and they can’t inspect it until they drive away. Those drivers are simply not on the dock anymore.
QA: For several FSMA rules, FDA provides training on many of the controls and requirements. Is that the case here as well?
BH: It’s more generic, and it doesn’t drill down to some of the real important things that may or may not be part of what you haul. Allergens are a perfect example. If they don’t wash that trailer after [hauling peanuts], as per regulation, they could cross contaminate the next load they haul, which could be some sort of vegetable. Some of that was not really laid out. It’s a good start, but I would suggest to some companies, you need to add that training. The regulation says you need to train to the specific requirements that the customer has.