FAQS
FSMA is the acronym for the Food Safety Modernization Act. There are seven separate rules that address specific areas of food production, shipping, and receiving. One of the rules covers transportation.
Here is the link to the FDA’s general description of the rule, but if you are interested in reading the text of the regulation, you can find it here.
This rule aims to ensure that how we transport food does not make food unsafe. The specifics of the rule cover sanitary conditions of a trailer, protecting temperature-controlled foods, specific responsibilities of ‘stakeholders’ (people required to comply with the rule), training, and recordkeeping.
The rule uses the term stakeholders to identify who is responsible for compliance and what they should be doing to comply.
If your company is unsure about its obligations under the regulation, it is important to review how your business activities touch the transportation segment of the supply chain. Control what you can control.
The identified stakeholders are:
Shippers: As defined in the rule, this is the company that secures the transportation of the food load. Whoever books the truck is responsible for complying with the rule, which means that this company ‘stands in the shoes of the shipper.’ Parties can include compliance responsibilities in contracts
Receivers: The company/party receiving the product.
Carriers: The company/party transporting the product.
Loaders: The company/party that is loading the product. This is typically the cooling or processing of the food.
**It is important to note that a shipper/company expects the loaders to manage compliance with the rule while the food is in the care, custody, and control of the loaders; these specifications must be written and communicated to the loading facility.
The FDA’s language about what ‘clean and sanitary’ means is vague. Still, 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.
If a company does not feel like they have the authority to require a business partner to comply, at a minimum, their expectations should be in writing and communicated to their partners (customers and suppliers).
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 knows 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, the refrigerated trailer is not included in the investigation process in a typical recall or traceback event. However, if the FDA requires proof of compliance during an investigation, a company has 24 hours to comply with the request.
1) Your customer should give you specifications (details) about how they want the trailer cleaned and how often it should be cleaned. If they don’t specify (in a contract or dispatch), you should be prepared to explain your company’s cleaning protocols/procedures. Document these cleaning events so that you have proof of your procedures.
2) Your prior cargo may leave your trailers dirtier than you think.
Suggested list of Must Clean cargo:
• Beef, chicken/turkey, pork, dairy, eggs, fish • Fresh produce: Cut veg and fruit debris/remnants, field dirt, and mud • Nursery- related such as live plants, peat, sod, fertilizers • Pharmaceuticals • Food products spilled or piled on the trailer floor (sugar products)
Dry cargo considerations?
Many companies that load dry freight (carpet, clothing, furniture, etc.) have mistakenly assumed that there are no contamination risks associated with dry freight. This has been shown scientifically to be incorrect. Protect your company against this misleading assumption and plan for a trailer periodic trailer.
In our humble opinion, a Healthy Trailer Clean is the only cleaning process that is scientifically proven to reduce risks in a food transport trailer.
Guidelines for performing manual washouts:
1) Prior to starting the wash, note areas on surfaces that may need extra cleaning. This way, the problem is addressed as you move from the nose to the tail, reducing the likelihood of returning to the trailer after the cleaning.
2) Clean under and around the bulkhead sections, particularly the floor, drain holes, and other areas that collect debris and dirt.
3) Start in the nose of the trailer, clean in 5 to 8’ sections, in this order: Ceiling, bulkhead, walls, floor, pushing the water from the sides to the center of the floor. This reduces the risk of cross-contamination from the floor to the walls.
4) As you finish the cleaning, check that the threshold areas, particularly the drain holes, are clear of dirt and debris.
5) If you choose to apply a chemical, make sure it is a food grade quat, and that it is applied according to the manufacturer’s instructions. If the trailer is at a commercial washout facility, check to see that the chemical is not pooling in the trailer.
Always refer to your customer contracts to meet their specifications.
Many companies rely on brooms and/or leaf blowers to clean their trailers. These tools may leave the trailer visibly clean. Some food companies have not developed trailer sanitation protocols and will be satisfied with a blowing or sweeping procedure. At a minimum, ensure your drivers understand what ‘clean’ is acceptable to the shipper’s loading inspectors before arriving at the shipper’s facility.
It’s a common misconception that only cargo can make a trailer dangerous for food. However, trailer surfaces are exposed to contamination in a variety of ways.
Air: The gentlest breeze can move particles and pathogens from outside the trailer to inside surfaces. Refrigerated air cycling through the chute and over the trailer floor can move pathogens around the trailer.
Water: Pooling and roaming water are common sources of contamination. Drivers prefer to have water at or around the threshold to show the loading inspectors that the trailer was washed out. This can be a sign of hidden contamination.
People: Scientific studies have shown that bacteria on shoes is a common cause of cross-contamination. Drivers, repair and service technicians, and loading and unloading crews are all possible sources of shoe contamination as they work inside a trailer. If these people need access, it is best to enter the trailers with shoe covers or make a convenient shoe disinfectant available.
Animals: Like people, animals, particularly birds, are likely culprits contributing to contamination inside trailers. The presence of feces, nests, fur, and feathers indicates that the trailer should be cleaned and disinfected prior to loading food.
At the loading facility:
Depending on the customer's specifications, the cooler management, or quality assurance (QA) employee, a driver may or may not receive food cargo.
The shipping crew will typically note the dirty conditions (including smells) on their loading documents and will only load the product once the driver returns with a receipt or other document showing that the trailer was cleaned.
Some facilities will require the driver to get a new appointment time while others will load the trailer as soon as the driver returns with a clean trailer.
At the receiving facility:
At the loading facility, receiving food cargo out of a dirty trailer can depend on the buyer's specifications, the receiving inspector, or a company's specifications. Rejecting an entire load at the receiving point is becoming more common due to questionable conditions. Bills of lading will be stamped 'Out of compliance with FSMA.