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Defensible Space

Does your transportation food safety plan protect your company?

Spring is here, and soon to follow is our first trip to the mountains to enjoy the cabin. Just thinking about it, I can almost smell the meadow and pine trees from here in Greenfield. It is a beautiful place in which to rest and enjoy.

But rest and enjoyment come at a price. There are things that must be done to ensure this wonderful mountain home is not placed in danger by our negligence.

This means that the first thing on our ‘to do’ list before we start our summertime trips in the forest is to create our ‘defensible space.’ Hours of raking and clearing needles and pine cones from around the cabin are critical to the preservation of the cabin should a forest fire start near the property.

As we get closer to this time, we start talking about how best to prepare for ‘opening day and the most important tasks on our ‘to do’ list. We take down the snow shutters, shoo mice (dead and alive) out of the house, set up outside furniture, and of course look for rakes to start the clean up job. Part of this discussion includes our best guess on how many needles fell during the winter, which of course translates to how much time it will consume before we can get down to the business of relaxing in the mountains.

This defensible space that we are required by law, and common sense, to clear around the cabin takes time and a ton of work. But it can be the difference between a building structure being saved or completely destroyed.

As I talk to different people about FSMA’s Sanitary Transportation Rule, our conversation has a ‘defensible space’ feel to it. Depending on who I talk to, the person views the rule as either a necessary evil or a great way to preserve something that is valuable, namely, their company’s reputation.

Not paying attention to the rule’s requirements is like leaving piles of needles and wood debris around a cabin in the woods during a hot summer. It’s just not worth ignoring the risks of not being prepared for bad things happening.

I have noticed that the people who have been closest to an actual food safety problem are very interested in Healthy Trailer LLC and the solution we offer for FSMA compliance. On the other hand, there are quite a few others who have not had the benefit of unwanted scrutiny of their transportation plans, and are therefore quite comfortable with their usual washout programs, both at home and on the road.

Until the FDA published the rule, food safety in the transportation industry was ‘unofficially’ happening in some companies, but in many others, developing a solid plan was entirely new and confusing. During the first year post publishing the final text, the FDA’s approach was ‘soft enforcement’ meaning that the focus would be on educating and training.

Necessary to consider then is that many companies did not truly understand their role in consumer confidence in the supply chain. This situation is similar to a person who had never owned a cabin in the woods prior to buying their mountain retreat. Truly appreciating the critical importance of cleaning needles and other wood debris would almost be overwhelming given all the other tasks and responsibilities that are part of cabin ownership.

Now that FSMA has placed these requirements on companies formerly left on their own in terms of creating, implementing and executing a transportation food safety plan, people will need help in understanding the importance of having defensible space around their transportation programs.

The other point that is important to mention is that I talk about ‘clean and sanitary’ trailers because this is the focus of our business. We have spent considerable time studying the trailer environment and how best to clean and sanitize a trailer, and we feel that it is our role to help others understand this important aspect (and requirement) of food safety.

But there are two other significant areas to consider in ensuring defensible space, namely, proper protection of food during transportation and proper temperature control in foods that require this for food safety purposes. Careful attention to both are an integral step in ensuring a company’s food safety plan is adequate and complete.

So here are some things to think about when considering the importance of defensible space.

First, clearing defensible space for people in the mountains isn’t really something you think about doing or not doing. It’s part of owning a mountain home. This clean area is valuable, and is not an option. It is a responsibility that is part of home ownership.

The same is true for parties now on the hook for safe food transportation compliance under the Sanitary Transportation Rule (STR.) If a company is growing, processing, moving, or receiving fresh produce, paying attention to and preventing risks that could endanger the product is not an option. It shouldn’t matter if there is a rule or not because being part of the supply chain carries a serious responsibility with it.

Second, no one who owns a cabin wants to think about the worst happening. But a forest fire is always in the back of our minds, and we pay attention to all sorts of details around the cabin to make sure we are not putting ourselves or others at risk.

It’s called being proactive. It may never happen, or we may have had a great rainy season that made the forest lush and moist, but just because the odds are in our favor does not diminish the fact that a fire could start at any time in a lightning storm or because of someone else doing something foolish in the forest.

When the STR comes up in a conversation, people often talk about how there has never been a documented food illness outbreak tied to unsanitary transportation. I think it is more accurate to say that there has not been enough research done yet on the consequences of a dirty trailer.

We have been calling carriers lately to introduce Healthy Trailer LLC to them as a new FSMA solution to provide their customers with clean and sanitary trailers. Lately, many of these companies, especially the larger fleets that have contracts with retailers and/or foodservice operators, are not willing to hope that they don’t get drawn into a food safety issue.

I am on Food Safety Magazine’s email list and read about how bad events happen. Unexpected issues arise all the time that create a problem for someone, and now, because of the rule, a company’s transportation plans are also subject to scrutiny. So it is similar to unexpected ways a forest fire may start. People need to know that it is smarter to be proactive and protect your space rather than hope the worst never happens.

After we have raked and hauled needles off to the dump for a few days, we are bone tired. Our hands are full of blisters, we can barely lift a cold beer to our parched mouths, and forget playing horseshoes for a few days.

But, we sure can sleep better knowing that we have done everything we can to make sure our defensible space is adequate and as clear as possible to help protect the cabin.

A company who has written and implemented a good transportation food safety plan can rest assured that their efforts to show compliance will help mitigate against the scary things that can happen in a food safety disaster.

The Sanitary Transportation Rule affects several areas involved in moving fresh produce, but lately my efforts have focused on the cleanliness of trailers. So when people tell me that their customers do not require them to clean their trailers regularly, or that they don’t need anything other than a receipt to show a washout, or that sanitizing is ‘overkill,’ it sure seems like they may find themselves unprepared to face a serious investigation into their transportation practices.

Finally, the truth about clearing a defensible space around the cabin is that this work is never done. A windy day, crazy squirrels and chipmunks, or other natural events in the forest are always causing more needles and pine cones to drop and create fire hazards throughout the season.

In other words, the work is never done. It’s part of ownership. Getting the space cleared at first is just the start. Hours of maintenance are part of the routine at the cabin.

How true is this also for a company that depends on transportation piece of the food supply chain? Compliance is never done. There will always be something to modify, revise, correct, improve, and so on.

But the rewards far outweigh the ‘pain’ of ensuring a defensible space. Taking this critical step in making sure your company's transportation practices are in compliance with the STR will free up time for you to do the things that make your business grow and flourish.

Get it done, then enjoy your space!

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