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Don’t Fear the New FDA Sanitary Transport Rule

By Dave Seddon, MBA RD LD (PEAKCORE, a ConnectFood Partner)

For many, change can be daunting. This includes the new FDA Sanitary Transportation of Human and Animal Food Rule. With increasing regulations, such as with the implementation of Electronic Logging Device (ELD), transportation companies are wondering what impact will this new rule have on the bottom line and operations. Fortunately, the changes that have come about since the 2005 Sanitary Transportation of Food Act, provide more flexibility and a preventative scope on top of the existing industry’s best practices.

The FDA’s Food Safety Modernization Act (FSMA) final rule on Sanitary Transportation of Human and Animal Food’s foundation is a “risk-based” model for food safety, clearly defines who is covered by the rule, and highlights certain preventative operational areas that help to ensure product food safety, such as temperature, is being maintained throughout the course of transport. The final compliance date for most businesses, barring any waivers, are upon us. We have provided a few bullet points of those requirements that are now being monitored to help you implement an improved food safe environment.

    ● The final rule establishes clear definitions of the transport role you play in transport. Those identified are Shippers, Carriers, Loaders, and Receivers. Some of the operational guidelines also will enhance and impact cGMPs (Current Good Manufacturing Practices) and SOPs (Standard Operating Procedures). Since, businesses can play multiple roles, a food safety plan should state each of these.
    ● FDA states “any movement of food in commerce by motor vehicle or rail vehicle,” all Transport Operations, Vehicles, and Transport Equipment are subject to the requirement.
    ● Temperature monitoring operations for foods are now required for temperature control safety. Thus businesses need to be able to provide temperature maintenance documents upon request. Clearly, these requests are becoming more prevalent and you should be prepared to show evidence for your clients.
    ● Training certificate and internal training programs are a few ways that businesses can illustrate compliance for training employees on food safe handling practices.
    ● The final rule requires maintenance and retention of records of written procedures, agreements, and trainings have been completed. Procedures should include ways to address pre-cooling, prior cargo handling (post), and vehicle/transport vehicle cleaning records. Cleaning, sanitizing, and inspecting of vehicles and transport equipment procedures must be written and maintained. Retention length depends upon the type of record and when the activity occurs.

Raising the bar for food transport adds to the increasing awareness that improved food safety transport systems strengths the diverse and complicated food procurement system. Creating a Sanitary Food Safety plan is a great way and first step for some to help your company meet many of these new requirements and ease the burden of compliance. Tools, such as ConnectFood, provide a resource for templates, models, and a framework to develop your own plan in short period of time. Best of all, all records can be maintained for ease of access for your client and the regulatory bodies. If you need further assistance, experts are available as well.

As always, ConnectFood is ready to help. A transportation plan guidance is available on the ConnectFood website, and a template with information is available to be loaded for your company upon request. Contact us.

About the Author
Dave Seddon, MBA RD LD (PEAKCORE, a ConnectFood Partner) is a food safety consultant with 25+ years of financial, operational, and managerial experiences in for-profit and non-profit organizations. He is well versed in food safety, SQF, HACCP, operational control, business development, entrepreneurship, M/A, risk analysis, and ERP/system implementation. Dave is a ConnectFood partner as part of the Expert Services.

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The Complexities of FSMA

The Food Safety Modernization Act (FSMA), which was signed into law in January of 2011, was created with the intent to regulate the way foods are grown, harvested, and processed. This rule allows the Food and Drug Administration (FDA) to step into the food safety chain to protect the public by assessing, regulating, and ultimately strengthening the food safety system. FSMA focuses on five main topics according to the FDA’s fact sheet, each of which has subtopics that relate to your food safety depending on the classification, facility size and employee count, and the purpose of your food company:

    1. Prevention
    2. Inspection and Compliance
    3. Response
    4. Imports
    5. Enhanced Partnerships

Back in November of 2016, we released a blog entitled “What is the Food Safety Modernization Act?”, which began our continuous discussion of FSMA. For the past few months, ConnectFood has been releasing blogs that touch upon the topics most relating specifically to the safe production and hazards around human food. For example, we discussed every aspect of record management regarding safe production, documentation, logs and records, and food safety plans. (Part 1, Part 2, Part 3, Part 4, Part 5, Part 6) We also discussed the importance of practicing mock recalls and the more specific and intimate details of recall planning and writing your food company’s recall plan.

Whether you are a food manufacturer, a distribution plant, a restaurant, small food producer, or anything in between, your facility or kitchen must be compliant with FMSA regulations. You should assume that an FDA Inspector will arrive to perform an audit on your facility at any time, on any day of the week. Sometimes, these visits are scheduled, but often, you should be ready for a surprise. Get ready to hand over your required documentation, explain your processes, justify your Good Manufacturing Practices (GMPs), and most of all, get ready to be expected to implement some changes.

Over the next few weeks, ConnectFood’s goal is to continue to educate you on the segments of FSMA and the regulations surrounding food safety policies. We will be having food safety experts write on the following topics:

1. Sanitary Transportation of Human & Animal Food
Sanitary transportation is an element of FSMA that has a rule finalized by the FDA. According to their online documentation, “The FDA Food Safety Modernization Act (FSMA) rule on Sanitary Transportation of Human and Animal Food is now final, advancing FDA’s efforts to protect foods from farm to table by keeping them safe from contamination during transportation… The rule establishes requirements for shippers, loaders, carriers by motor or rail vehicle, and receivers involved in transporting human and animal food to use sanitary practices to ensure the safety of that food. The requirements do not apply to transportation by ship or air because of limitations in the law.”

2. Foreign Supplier Verification
The final rule on foreign supplier verification began implementation on May 30th, 2017. The online documentation states: “The final rule requires that importers perform certain risk-based activities to verify that food imported into the United States has been produced in a manner that meets applicable U.S. safety standards. This rule is the product of a significant level of outreach by the FDA to industry, consumer groups, the agency’s federal, state, local, tribal and international regulatory counterparts, academia and other stakeholders.”

3. Preventive Controls for Animal Food
As you know, ConnectFood talks about human food constantly, but there is equal importance in making sure our pets are fed safely. Let’s not forget our furry friends in our safety planning. Check out the FDA’s final rule fact sheet here until we release our blog on the subject.

4. Strategies to Protect Food from Intentional Adulteration
Intentional Adulteration is not a topic to skim through – we will be having our own Kathy Knutson, Ph.D., PCQI, (who is trained in the prevention of Intentional Adulteration) write a post focusing solely on the topic. Until you get to read her writing on the subject, take a read through of the FDA’s webpage here.

All of this information may be overwhelming no matter if it is old news or fresh news. As always, if you have any questions regarding FSMA and how it relates to your food company, the team at ConnectFood is always here to help. Don’t hesitate to reach out for help if you need it. The time for compliance is the present – don’t be caught without a FSMA-compliant food safety plan in place. Contact us.

About the Author

Johanna Seidel, PCQI

Johanna Seidel is an administrative member of the ConnectFood team, where she works as manager of operations and manager of social content. Johanna received her Preventive Controls Qualified Individual (PCQI) certification in November of 2017. She received a Bachelor of Fine Arts Degree upon graduation from West Texas A&M University in May of 2016. When she is not working with food safety experts, Johanna also works as a dance instructor for The Chicago School of Ballet, as well as a professional contemporary dancer in the city of Chicago.

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