#FirstInFSMAClean: Pioneering the Path to FSMA’s Transportation Rule
And one Less (Very Big) Thing for You to Worry About
We’ve been working on our latest brochure. While it sort of takes some time and effort thinking of the best ways to tell our story, spending time crafting our message to accurately describe what we do and why we do it reminds us of why we started Healthy Trailer LLC in the first place.
Claiming bragging rights to being the first one to develop a science-based FSMA compliant trailer sanitation station is awesome, but as is true for probably most pioneers, making something new that greatly improves a marginal yet accepted process (like the usual trailer washout) takes a great amount of persistence and creative thinking.
When the FDA published its safe food transportation requirements, many people involved in the food industry failed to see what was new and different. For them, it was business as usual, no changes planned in how they ensured their trailers were clean.
But for other companies, FSMA’s Sanitary Transportation Rule scrubbed up from the industry a new customer, particularly those for whom ‘clean’ made sense. We had a hunch that there would be a growing number of companies who would see this rule as an opportunity to implement greater safeguards in their food shipments.
Who are these ‘clean conscious’ companies? And notice how Healthy Trailer has members from each group named in the rule who need to be FSMA compliant.
Carriers looking for professional sanitation services that make compliance easy and convenient for their drivers while at the same time prove to their food customers that they are FSMA compliant;
Shippers who have specified that their fresh product will be transported in clean and sanitized trailers;
Cooling facilities that want to eliminate the guesswork for their loading personnel in making decisions about whether a trailer is clean; and
Recievers who want to ensure that their fresh product is being transported in clean trailers.
Aligning our science and standard operating procedures with the other food safety concepts in FSMA, Healthy Trailer LLC built its first trailer sanitation station, offering our cleaning and sanitizing system to specific customers who were determined to find a FSMA compliant trailer sanitation service.
What are the facts about Healthy Trailer LLC that puts our trailer sanitation service as the leaders in this niche (one that we actually created) of FSMA clean?
Following the FSMA Pattern
First of all, Healthy Trailer was designed from the ground up based on the typical FSMA pattern.
1) Identify the risk
2) Prevent the risk
3) Define the activity that will prevent the risk-How will you do this?
4) Document the activity that shows the risk has been prevented according to SOP’s.
This is the progression that HT followed from the beginning:
1) Risk: Potential contamination from prior cargo;
2) Prevention Method: Clean ‘prone zones’ (collection of organic and inorganic material that collects on trailer surfaces, especially the floors) AND sanitize the surfaces with germicidal UV light;
3) Activity or process that will successfully prevent the potential contamination:
a) Automate: Reduce inconsistent cleaning procedures caused by manual labor.
b) Nozzle arrays/selection: Spray patterns that rinse surfaces, not spread contamination;
c) Utilize germicidal UV light engineered by UV specialists for Healthy Trailer application in food transport trailers, specifically the fresh produce industry;
d) Develop and execute SOP’s that maintain Healthy Trailer quality assurance standards; Routine use of ATP, UV dose cards and TPC tests based on food safety auditor recommendations;
e) Validate and Verify service with 3rd party food safety audit services
4) Document the service completed in each trailer; seal to maintain ‘clean chain of custody’ for customers.
HT’s List of Firsts
First to accept the FDA’s FSMA ‘clean and sanitary’ regulation and turn it into a call to action.
First to test surfaces using ATP technology with the specific intent of understanding the actual ‘clean and sanitary conditions of OTR trailers (Over The Road.)
First to define ‘clean and sanitary’ based on ATP results in OTR trailers AND based on the level of clean accomplished in a validated HT clean and sanitize service.
First to design and use an automated machine that didn’t ‘duck’ the responsibility to clean ALL the surfaces in a 53 foot trailer, thereby rejecting the ‘avoid problem areas’ process used by commercial washout facilities.
First to Test:
-Our site water (3rd party lab)
-Our water coming out of the nozzles (3rd party lab)
-Our nozzles, tires and other machine components and surfaces (ATP)
-Our UV lamps (Certified radiometer, UVDI dose cards)
First to recognize the hazards and shortcomings of typical application procedures of chemical sanitizers;
First to research, develop and implement germicidal UV technology as a viable alternative to typical sanitization processes offered to the food transport industry; and
First to provide FSMA traceability with HT’s certificate and seal program.
What does FIRST place give us?
Because Healthy Trailer created this FSMA clean niche, we believe that being first makes it our responsibility to keep the food transportation industry moving forward in understanding and practicing professional trailer sanitation.
This means that we need to continue with our research in best practices, and as we learn, we are committed to communicating our findings as well as proceed in relentless innovation mode to improve our own service and process.
We believe that we have a role in assisting our competitors to become more aligned with FSMA’s expectations. This responsibility may include sharing our science research and how it can advance their washout procedures. All washout services should have their customer’s FSMA compliance as a top priority, and we can help with that objective.
Finally, the number one job Healthy Trailer owns and cherishes is the duty and privilege of serving our customers, particularly those who saw from our very beginning that this level of clean and sanitary in food transport trailers was long overdue. Further, these people understood that investing in clean and sanitized trailers not only made sense, but also, it safeguarded their product, their brands, and finally, the end consumer.
For sure, Healthy Trailer LLC believes that FSMA compliance is an ongoing pursuit of applying the most up to date science, tools and food transportation knowledge to our practices. Being #FirstInFsmaClean puts us in the ongoing leadership role discovering how best to keep food transportation trailers clean and sanitary. We accept the challenge.