I am pleased to share a guest contribution from my Western Growers colleague, Ken Gilliland, Director, International Trade & Transportation. This blog will highlight the new FDA Sanitary Transportation of Human and Animal Food Requirements.
As a shipper/loader you are subject to FDA records requirements, and are responsible for ensuring the carrier equipment you are about to load is in appropriate sanitary condition, specifying in writing all necessary sanitary specifications. While this may sound like a daunting task, you as a shipper are likely already meeting most, if not all, of these requirements. It may require you verify your current record retention of loading and shipping documents to ensure you are compliant. As a shipper/loader, by April 6, 2017, you will need to implement written procedures, which must be retained for 12 months.
Your bill of landing no doubt contains all the essential information needed to ensure appropriate temperature guidelines. Regarding the issue of sanitary transportation, if like most, you probably have a pre-check/load form. If not click here to access a pre-check/load form that you can personalize for your operation. This pre-check/load form combined with your bill of lading should meet all the responsibilities the FDA has required of you as the shipper/loader.
The purpose of this FDA rule is to ensure use of sanitary transportation practices so that all food for both human and animal consumption, is transported under conditions that will prevent food from becoming adulterated. Under the rule, the FDA allows current industry transportation best practices concerning cleaning, inspection, maintaining, loading and unloading, and operating vehicles and transportation equipment used to transport food, and by focusing the rule strictly on public health risks associated with transport and not quality. Many people think produce is covered under the temperature controlled rule, but most produce is not—with a few exceptions, it’s more commonly only subject to the open container portion of the rule. This distinction is important, as the purpose is not to create undue burden or throw away product which is safe for human or animal consumption.
So as a shipper/loader you need to provide the following in writing:
- Ensure adequate temperature control is provided during transit.
- Ensure equipment used in the transportation is in appropriate sanitary condition to prevent food from becoming unsafe.
- Before loading, determine the trailer is in appropriate sanitary condition, e.g. it is in adequate physical condition, clean and free from visible pest infestation and any previous cargo that could cause the food to become unsafe.
- The equipment is adequately prepared for transportation, including that it has been properly pre-cooled.
As you can see the linked document should cover all the basic requirements. Finally, always be sure that both your personnel overseeing the operation and the driver sign both the pre-check/load form and the bill of lading.
On a final note, it would be prudent for you to confirm with your transportation broker/third party logistics provider that they are familiar with and adhering to the provisions of this regulation, as they assume some of the responsibility. The FDA defines a Shipper as the manufacturer or a freight broker, who arranges for the transportation of food. The good news for those of you utilizing the Western Growers Transportation Program, managed by C.H. Robinson, is that they are well ahead of the curve already ensuring the carriers they select are pre-cleared and will be in full compliance (click here to view CH Robinson’s short video commenting on the rule). This is just one more added benefit members of Western Growers enjoy when taking advantage of the Transportation Program.
In closing, should you have any questions of Ken Gilliland, or wish for me to review your current pre-load and loading documents, please email us at TommyO@wga.com or call Tom Oliveri at 949-885-2269.