Do You Need A FSMA Monitor
School is back in session, and by now the Fall semester is well underway. Classroom procedures and schedules that were set a few weeks ago are now becoming routine.
A few things that are not working may need revision, but for the most part, the students know what is expected and the structure that comes with organization is helping them get on with the business of learning.
I was like most elementary school teachers, implementing a Monitor System during the first week of school. Certain repetitive tasks could be effectively completed by the students themselves, which freed up time for me to get my job done, teaching kids.
We had a Flag Salute Monitor, Library Monitor, Attendance Monitor, Ball Monitor and some years, depending on my class roster, I would also create a Small Group Monitor and a Supplies Monitor.
Some of these positions were very much coveted, particularly the Library and Attendance Monitors, because these students got to leave the room and their classmates behind, at least for a short while.
It only took one year to really learn how to best develop and implement a meaningful monitor system. There were definitely some do’s and don’ts to remember, and most often this was in relation to which student I selected to start our year.
Of course, I had to choose well initially. These students needed to have great modes of trustworthiness and efficiency so that their watching classmates could observe what my expectations looked like in practice.
After the routine was routine, then I could stagger the students who may be more challenged to get things done as planned. Of course, they needed to participate, but sometimes the accountability was too much for some kids and they just preferred to pass on a job.
This system did several things that eventually contributed and lead to a very successful school year.
First, having monitors gets procedures organized fast.
Second, it makes the students more responsible and engaged in the process.
Third, the weaker could observe the stronger and learn from them.
Of course, all of this critically depended on my support of each student so that the end result was that they felt like they had contributed something of value to the classroom, and me, which is always important to students.
I decided to share this story because I believe that companies can benefit from establishing a monitoring system for their food safety compliance plans. This is particularly true for those of us now required to comply with the FDA’s Sanitary Transportation Rule (STR).
Of course, every company’s plan should have people responsible for doing certain tasks and making sure those actions are documented. The rule actually specifies that One person should be designated as the Competent Supervisory Person in charge.
But that is not what I am talking about here. I think that a company should step away from the details specified in the rule and get that ‘30,000 foot’ perspective to really understand how to best comply with the STR.
I mention this because as we have built Healthy Trailer LLC from the beginning question of ‘What is a clean trailer?’ to where we are now, providing a science based trailer cleaning service, I have had the opportunity to learn about what is actually happening in the transportation industry in the area of providing clean equipment as required in Section 1.906.
It has been an eye-opening experience! Companies from both the transportation and fresh produce industries have varying levels of awareness about the rule in general, which means that complying with different part of the rule is equally varied.
For example, on the topic of cleaning and sanitizing a trailer (or whether the rule even requires sanitation) ask different people from either industry and you may get 10 different answers.
This is just one area of compliance. There are several others in the STR that need attention. Just like in a classroom, it may help to have a system whereby a company assigns a specific responsibility to qualified partner to ensure compliance.
The system starts with a few questions.
What do we know needs to happen, and who do we want to trust to make sure that happens correctly to keep us compliant?
The rule is structurally helpful. If a company works through the sections to implement Monitor categories, they might find that they need an Equipment Monitor who is their preferred trailer manufacturer with a specified reefer unit. Some companies have a Trailer Cleaning Monitor that is in charge of the Standard Operating Procedures that demonstrate a trailer has been cleaned according to the rule’s expectations or a customer’s specifications, and that the cleaning has been documented.
Other vital STR Monitor positions could be Emergency Monitors, Training Monitors, Communication Monitors, and so on. One of the good things about this rule, and the FDA says this in the rule’s text, is that the rule is not ‘prescriptive’. This means that a company, viewing their compliance obligations from the 30,000 foot view, has flexibility in deciding how to best accomplish getting a plan in place and working well.
What is not optional is the requirement to comply with the STR. Not only is there an enforceable rule now, but equally concerning is the volatile food safety environment. There have been fresh produce related illness outbreaks, and consumers are getting sick. Add to this set of circumstances the overall industry confusion and uncertainty of what the rule actually requires, and it is easy to see the need for a solid, dependable STR Monitor system.
A classroom can function without monitors. Many do well without this type of structure. I am ‘organizationally challenged’ so having monitors to support my educational efforts was very helpful. More times than I care to admit I would have a monitor remind ME of something that needed to happen rather than the other way around.
But, isn’t that the purpose having a strong system to help get important things done?
Your company may not need a Monitor system, but maybe at least consider implementing some form of structure. Not only will you end up with a compliant transportation plan, but you will give people who your company depends upon valuable accountability, experience and knowledge that will come in handy down the road.