The transportation requirements for the Food Safety Modernization Act (FSMA) should be released March 31 this year, with enforcement to begin March 31, 2017. (Photo by Sean Kilcarr/Fleet Owner)

Refrigerated carriers need to take lead in food safety compliance

March 21, 2016
Temperature data won’t be enough for compliance, warn experts.

New food safety rules headed towards the transportation industry at the end of the month will force refrigerated carriers to make a bevy of operational changes – and those changes may need to be made well ahead of the 2017 compliance date set for those mandates, according to Hugh Latimer, COO for Iron Apple, a food safety compliance firm.

“It’s coming down sooner than that, because shippers are demanding it,” he told Fleet Owner. “Shippers are the ones held responsible under the new [food safety] rules.”

The reason refrigerated carriers are in the crosshairs, however, is that the requirements transfer a lot of transportation risk and responsibility for food safety during transit to them, Latimer stressed.

“You must prove that you are following [safety] protocols now; you must prove you are washing trailers between loads, what cleaning agents you are using, and what training your drivers have received and are practicing,” he emphasized. “You must document what you are doing on a continual basis because if there are problems, you’ll need to be able to explain yourself or you’ll be left holding the bag.”

By “holding the bag,” Latimer means carriers whose loads are rejected may not be able to receive compensation from either the shipper or receiver if they cannot properly document their food shipment practices. “A lot of carriers think if they can document shipment temperature while in transit then they are covered,” he said. “That’s not nearly enough; there is quite a gap between what carriers think is needed and what is actually needed.”

Chip Powell, director of operations for telematics provider Blue Tree Systems, stressed to Fleet Owner that readily available technologies can help refrigerated carriers gain that compliance.

“Take trailer washing: you can put a ‘geofence’ around a wash bay location and then link that data back to a wash ticket, providing ironclad information that your truck was there and properly cleaned,” he said. “The hard part is that carriers may need data at a moment’s notice so providing such documentation electronically will be critical.”

Iron Apple’s Latimer pointed out that refrigerated carriers should formulate a rigorous preventive control plan or “PCP” to ensure they’ve established a compliant food safety program. That plan should cover:

  • Employee knowledge, hygiene, health
  • Food handling procedures
  • Equipment maintenance and cleanliness
  • Facility cleanliness: for example, documenting pest control protocols at freight terminals
  • Process control
  • How to handle complaints and recalls

He added that carriers will need to follow five steps to ensure their PCPs are being implemented correctly:

  • Evaluate the hazards
  • Specify what preventive controls need to be put in place ahead of time
  • Specify how these controls will be monitored
  • Maintain routine records of these monitors
  • Specify what actions will be taken to correct any problems that may arise

Latimer emphasized that refrigerated carriers should take the lead in establishing such plans. “What we tell carriers is that shippers can make you adopt whatever plan they come up with to be compliant – and if you have five different major customers, you might be facing five vastly different food safety plans,” he said.

That’s why Latimer emphasized carriers should either develop their own plans or adopt one developed by a third party; then demonstrating to their customers that they are compliant.

He added that such plans, if imitated early and thoroughly, can prove to be something of a competitive advantage in the food transportation business, based on Iron Apple’s experience with Canadian carriers.

“Over the last two to three years we’ve seen early adopters use their procedures to grow their business in the food market,” Latimer explained. “Not only did it help them preserve existing contracts, they won new ones as well.”

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