As the 2019/20 Yuma season approaches, once again here at Healthy Trailer we are busy getting our winter business organized. The ‘to do’ list is full of jobs that must be completed before our first customer trailer pulls in for a washout.
Fortunately we have a system that keeps things moving along. It started with my father who uses this ‘R’ question as a strategy to get people moving on things that need to get done. While I can’t say I always like the pressure that comes with the assignment, the process does get people focused on what needs to happen by a given date. Tasks get completed.
As we plan and add things to our list, we assign the ‘R’ to a team member. This is the responsibility to get the specific item either completed or have a very solid reason that it can’t be done at this time, all by a specific date.
Where this system becomes highly effective is in generic areas of responsibilities. Or, sometimes there are things that need to get done that no one wants to do because it involves a challenge or complication that will take some serious effort to resolve before the task can get completed.
Every successful business has these jobs that people really don’t want to do. But getting them checked off the list is essential.
It’s a system that would be helpful in companies struggling to get their FSMA transportation compliance done. In one of my companies, we work directly with their trucks to help them understand and meet the requirements. Here at Healthy Trailer, we are always talking to people who need to comply, but we often hear that it’s somebody else that has the ‘R’ to take care of it. So from first hand experience in both companies, I can see that compliance is challenging and that’s why someone having the ‘R’ is critical.
Part of the problem is perspective. From where they operate, they see compliance as something that others are or should be doing. It’s sort of like the old fable about the six blind men that all had a different description of an elephant. Because they could not see the whole animal (picture,) they made conclusions, and defended them, from their limited experiences.
Here are some of the comments that we hear that show how companies are thinking about FSMA compliance.
The shipper says, “I don’t get the truck..”
The carrier says, “No one makes me.”
The receiver says, “It’s the shipper’s job to specify.”
And the loader says, “Someone needs to tell us what they want.”
Everyone has their own opinion about who should be complying. The end result is that many fresh produce trailers are loaded in less than sanitary conditions.
Clearly, because they included safe food transportation requirements in FSMA, we can see that the FDA intended that someone involved in the shipment of food has the ‘R’ for compliance. And for added incentive to get compliant, it seems that there is increasing scrutiny on the supply chain, and specifically the transportation piece.
The reluctance to step up and take the ‘R’ challenge is sourced from underlying concerns and uncertainties. While these may not account for all the reasons why compliance has been put on hold, there are still significant barriers to moving forward.
First, requiring supplier or customer to adhere to new or modified transportation practices will probably disrupt some very solid and profitable business relationships. It takes a lot of work to find a competent transportation vendor. Intervening in its operations could potentially and irreparably damage that critical relationship. Who wants to do that?
Second, the trailer environment is an unknown from a contamination standpoint. But there is no doubt that trailers are carrying microbiological loads when it transports food. Here at Healthy Trailer we have been working through the first phase of verifying our trailer sanitizing process. TPC results in both long haul and field trailers definitely show that trailer sanitation is necessary.
This leads to a third barrier to compliance. In the area of trailer sanitation for example, there are as many opinions of what ‘clean and sanitary’ means as there are companies that should be complying with FSMA. In other words, standards of how this requirement should be met vary from company to company.
It’s interesting to note that the juice industry saw this problem coming as the FDA was writing the rule. Instead of taking an uncertain ‘wait and see’ position, they proactively supplied the FDA with washout procedures that they had previously written in an effort to standardize the cleaning process for their industry. The FDA specifically noted these specifications in the rule so that now, juice industry members are not confused or uncertain about washout procedures.
It seems that the overall problem underlying non compliance is that food safety concerns and practices are new to the fresh produce transportation industry. It is true, companies can continue to use accepted best practices to be somewhat compliant. But as we learn more about trailer environments, sources of contamination and best methods of reducing this contamination, inadequate former best practices will need to be revised and ultimately become standard operating procedures that are actually implemented, completed and documented in a company’s food safety plan.
Over the years temperature management was seen as the only big issue in produce transportation. Then, food safety professionals realized that microbiological issues in refrigerated trailers should also be managed with the result that FSMA included the Safe Transportation Rule. It is true that companies can continue to use older, accepted best practices to be somewhat compliant, but more must be done to be fully compliant. Food safety plans must include using trailer cleaning and sanitation procedures including appropriate documentation.
So back to the original question, who has the ‘R’ in your organization to get your company compliant with the FDA’s safe transportation rule? Regardless of where you fit in the supply chain, does your food safety plan address proper trailer cleaning and sanitation?
And don’t forget that usually the ‘R’ comes with a timeline. Considering that the rule has been official for two and a half years, probably sooner than later