FSMA full compliance date draws nearer

Feb. 23, 2018
Learn exactly what is required to comply with the FDA Food Safety Modernization Act, which has a full compliance date of April 6, 2018.

The US FDA Food Safety Modernization Act (FSMA) Sanitary Transportation in Human and Animal Foods full compliance date for all impacted shippers, carriers and receivers of human and animal foods is April 6, 2018. All training, food safety transportation plans, system improvements and complete documentation must be in place by that date.

More than 64,000 US companies are impacted by requirements established by the 2011 passage of this FSMA rule. The last major set of rules requiring full compliance for large and small companies was published in April 2016. These rules established April 2018 as the final date for full legal compliance for all carriers by road or rail. To date, thousands of US carriers have not yet provided training for loaders, unloaders, drivers and all personnel involved in food transportation.

For companies to comply, besides training, the rules require substantial improvement to procedures and processes involving sanitation and temperature controls designed to prevent adulteration of human and animal foods during transportation processes. Substantial written agreements between shippers and carriers must also be established, and new documentation systems must be in place to provide evidence of rule compliance.

The shortage of support infrastructure involving container and trailer sanitation and the lack of specification by shippers and carriers regarding adequate sanitation procedures is causing many companies to ignore rule compliance.

•Each company needs to develop a food safety plan that focuses on the transportation of food. Most companies already have a food safety plan, and the transportation part needs to be added to the company food safety plan.

•Company management needs to approve the plan and monitor its implementation.

•Procedures for temperature monitoring and sanitation of trailers must be written, people trained, and implementation monitored. How this is done depends on what foods are transported and customer needs.

•There needs to be a written agreement between the shipper or carrier company and its customers regarding who is responsible for what (sanitation and temp monitoring).

•All transportation operations personnel (loaders, unloaders, drivers, supervisors, etc) must go through mandatory training (three courses are specified by the FDA). Training certificates should be kept on file.

•Each company needs to look at two primary planning and implementation issues:

—In-transit issues:  Acceptance at load and unload according to written procedures and hazard control specifications, data related to sanitation and temp monitoring during transit, trailer pre-cool, security, reefer breakdowns, prior loads, driver acceptance and many others.

—Ground operation issues that include sanitation and temp control of the load and unload environments (tools, conveyors, floor jacks, mops, brooms, etc).

The Sanitary Cold Chain provides all compliance standards, online and on-site training, help with planning and procedure development, and documentation solutions for impacted carriers, shippers and receivers.

Email [email protected] or phone 808-469-0046  to obtain assistance.

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