FAQ

A ‘healthy trailer’ is a trailer that is clean and sanitary for the food cargo it will be transporting. Think of your own refrigerator at home. Most people are not comfortable putting their fresh (and increasingly expensive) food in a place that looks or smells dirty. They want to eliminate germs and bacteria that may contaminate their food. Speaking of people, this is where the definition of a ‘healthy trailer' gets a bit vague. Some people really don’t care much about whether their fridge is clean, and ‘clean enough’ is good enough. Other people are super cautious and practice ‘clean and sanitize’ protocols on a daily basis. And some of us fall somewhere in between. So ‘healthy’ means different things to different people. This is why a company must define (FSMA uses the word ‘specify’) and communicate its expectations to their suppliers and carriers. Otherwise, your trailer will be cleaned to the standard that they think is adequate.

Contamination may be invisibly collecting somewhere in the trailer environment. Just as pathogens can be found in processing plants, shipping totes and bins, and facilities, so too unsafe and unsanitary conditions can be found in trailers. People, air, cargo, water, and equipment all can contribute to potential contamination. Pathogens are not picky about how they move around, so not only are they on shoes, pallets, in the air and water, and forklift tires, but even cleaning methods (known as ‘current best practices’) like brooming, blowing or splashing contaminated water will seem to visually make the trailer look clean, but will spread pathogens in a way we can’t see. Without good (hygienic) trailer sanitation routines, unhealthy (harmful, unwholesome and possibly injurious) conditions can help pathogens thrive in a food transport trailer.

The authors of the FDA’s Sanitary Transportation Rule did not define what exactly this means, which gives its stakeholders options on how they want to comply with the regulation. Choice #1: Continue to use ‘best practices', cleaning methods like brooming, blowing or water rinsing, if and when necessary (visible debris and/or odors,) sometimes followed by a chemical treatment for sanitizing. There are commercial washouts where employees manually spray out a trailer with a pressure washer. And there are automated machines that wash the floors and walls of a trailer. Some of these also can automatically apply sanitizing chemicals. Choice #2 : Implement a sanitation protocol (SSOP) for trailers that mirror current SSOP’s in food processing/shipping facilities for Zone 2 or 3 non contact food surfaces. This will keep your food safety program consistent. At a minimum, any FSMA stakeholder that considers compliance with the Sanitary Transportation Rule important should be documenting the procedures that they are using to keep food safe during their transportation activities. Choice #3: If your company is loading fresh produce out of the Salinas Valley or Yuma growing regions, Healthy Trailer does Choice #2 for you. Refer to What is #healthytrailerclean to find out how we ca help you upgrade your trailer sanitation protocols.

No one really knows the answer to this question. This is because the FDA and companies working through a foodborne illness outbreak typically start with the food producer. Also, because trailer surfaces are not ‘typically' considered to be food contact surfaces, trailers are not considered ‘risk factors’ in the food supply chain. Anyone working directly with trucking companies and their drivers know that food does touch trailer surfaces, and depending on the driver, this can happen more frequently than assumed. The FDA noted specific instances of dangerous, unsanitary transportation conditions in its rule, and these instances were one of the main reasons they included a rule in FSMA specifically for transportation. To date, most food and transportation companies do not have a testing SOP to show that either their trailers are clean for food, or that their washout processes are in ‘clean and sanitary’ condition prior to loading a food cargo. Both total plate count (TPC) for microbial levels and adenosine triphosphate (ATP) sampling will help evaluate environmental conditions in trailers. Also, in a typical recall or traceback event, the refrigerated trailer is not included in the investigation process. However, if the FDA requires proof of compliance during an investigation, a company has 24 hours to comply with the request.

One of the most frequent objections we hear about why a company does not require drivers to provide documentation at the shipping facility to show that the trailer has been cleaned is that they can’t ‘make’ their transportation vendors to it. A load tender or dispatch requires a trucking company to: 1) Pick up product at a specific location; 2) Precool the trailer; 3) Arrive at the facility by appointment, or at a minimum within a specified time period; 4) Confirm product package counts (and sometimes type); 5) Maintain specific temperatures; 6) Report (or make available) location updates while in transit; and 7) Deliver at a specific location on a specific date. This is a short and incomplete list of specifications that a trucking company and their drivers are already required to do. The point is that trucking companies are already required to follow loading and unloading instructions. Also, even though the FDA’s language about what ‘clean and sanitary’ mean, it is very clear that it grants the stakeholders who are responsible for the safety of food cargo the ‘authority’ to specify, in writing, the protocols they decide are necessary to keep food safe during transportation.

There are a few factors that affect the ‘dollars and cents’ price of keeping a trailer clean. 1) Frequency of cleaning procedures: If a trailer is cleaned by a trained and experienced person before each food product load, an average cost of a professional washout procedure is between $40 and $60 per service. When a trailer is not routinely cleaned and debris is allowed to collect in areas known to harbor contamination, typically additional service fees will increase the cost of the cleaning/washout to $75 and as high as $100. 2) Prior cargo considerations: There is a common misconception that only protein based cargos require a washout prior to loading. However, other types of cargo (chemicals, dry, sugary products) can also leave not only visible residue, but also excessive amounts of packaging material. 3) Geographical locations and after hours services: Trailer sanitation/washout facilities near high volume unloading locations like ports and large cities charge higher prices. Drivers prefer to get their ‘housekeeping’ chores done when it’s most convenient, which is typically right after they get their load delivered. Late night and early morning unloading appointments often result in drivers needing washouts during non-business hours. Mobile washout services will meet the driver somewhere convenient for both of them, but prices on these special odd hour and mobile services can be

The consequences of arriving at a shipping facility with a dirty trailer may be: 1) Nothing. It is true that loading inspectors and QA employees will ‘pass’ a trailer so that product gets shipped and delivered on schedule. 2) The driver is asked to pull away from the dock and come back after the trailer can pass a ‘see and smell’ test. 3) The driver is told to leave and not come back without proof of a washout. 4) The shipping facility reports to the logistics superiors about continuous problems with carriers who arrive with dirty trailers. This is a 'red flag' that can cause loading delays and tighter inspection procedures for a trucking company. 5) Nothing at the shipping facility, but a rejection at destination with ‘Rejected: Out of FSMA Compliance’ noted on the bills of lading.

Honestly, you may already be paying for it. Are you getting what you are paying for? If you are a food or trucking company that requires a washout and are either paying directly or reimbursing for trailer sanitation, it may be worth having drivers who are getting the washouts report on the quality of the service. We’ve heard quite a few stories about commercial washouts that charge for cleaning services that are not completed according to a protocol or worse, leave the trailer visibly dirty. This requires a driver to get the trailer washed out a second time because of chemical residue left after an improper sanitizer application. Imagine the frustration for a driver who has complied with the washout requirement who at the dock gets told to go do it again because the trailer is either still dirty or has sanitizer pooling somewhere in the trailer. Now the $50 washout costs $100, plus the time it takes for the driver to get the process done all over again. A word about contracts… There are food companies that have contractually agreed to pay for trailer sanitation services. Without a system in place that routinely monitors this piece of a food safety program, a company may be paying for something that is not happening in accordance with the contractual agreement.

For a manual trailer washout in a ‘typical’ Over the Road (OTR) refrigerated 53’ trailer, completed according to a procedure that includes washing all surfaces (walls, ceilings, floors) from the bulkhead of the trailer to the threshold the process can take 30 to 45 minutes. This does not include any preclean/inspection or a chemical sanitizer application. A ‘typical’ OTR has minimal packaging debris after unloading, and perhaps a few spots of cargo debris. This can include protein based material (blood, egg, milk, decaying fresh produce,) food remnants from broken packaging, and wood pallet pieces. Many commercial washouts don’t clean walls or ceilings because of the time requirement, and also because they assume only the floor areas are likely to harbor contamination risks. Automated washouts vary depending on the preclean methods, their machine washing cycles, and optional chemical applications. An average automated clean and disinfect process at Healthy Trailer will take an average of 25 minutes, from driver check in, inspection and preclean, rinse and disinfection cycles, and last, final paperwork (HT Clean Cert/payment receipts) and door seal placement. The time consideration that is frequently overlooked when the trailer is not clean prior to loading food cargo is the time that it takes for a food facility to inspect a trailer for cleanliness. If the trailer does not pass the ‘see and smell’ test, the driver is sent away to get the trailer cleaned. This can take anywhere from an hour to the next day. To see what this looks like, visit the loading facilities that you use and observe the process. It may be perfect for your operation. Better yet, find out when a shipment of your food is loading so that you can check out the equipment that is used to haul your food. Are truck brokers required to comply with FSMA? Yes, the FDA specifically says the brokers are ‘shippers’ because they arrange for the transportation of food loads. Brokers should be communicating your specifications, in writing, to any carrier transporting your food cargo. A good practice for your brokers should be to provide you with their current food safety protocols, particularly if they have signed your contract for transportation services.

Yes, the FDA specifically says the brokers are ‘shippers’ because they arrange for the transportation of food loads. Brokers should be communicating your specifications, in writing, to any carrier transporting your food cargo. A good practice for your brokers should be to provide you with their current food safety protocols, particularly if they have signed your contract for transportation services.