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Implementing Trailer Sanitation Protocols

Preference-based or Science-based?

Who’s picking pumpkins for your porch this year? The pumpkin patches are abuzz with frenzied people trying to find the perfect pumpkin for the season’s festivities.

What is the perfect pumpkin? There are pumpkin patch protocols, right?

Long or short stems? Bumpy or smooth skins? Do you choose tall and skinny, or is your preference short and squat?

Every year, there seem to be more choices in color, size, and type. I found the patch to be a little stressful. Too many decisions…

Choices are often made based on preferences. And often, a person’s preference makes sense. In other situations, a decision made based on a preference can lead to negative consequences.

Safe food transportation is an example where programs and policies, specifically those shaping trailer sanitation protocols, can end up being poorly impacted by people and their preferences.

The debate about whether the FDA’s rule on safe food transportation is an ‘add on’ or is vague and poorly written is losing ground to a more common sense approach to ‘clean and sanitary’ trailer conditions.

As consumer voices get louder and FSMA compliance gets closer, many of us involved in food transportation are taking a more proactive approach to building and implementing protocols.

The pumpkin patch gives us a perfect opportunity to think through the protocol-making processes we use in our companies as we work towards a safer food supply chain.

Here are some questions to get us started:

  • How do people’s preferences have a negative impact on our trailer sanitation protocols?

  • How can you tell if preferences influence your food safety decisions?

  • What steps can you take to ensure science and proven food safety strategies guide your protocols?

Being in the business of trailer sanitation for the fresh produce industry has given Healthy Trailer many opportunities to understand the unique challenges of keeping trailers clean and sanitary. Not only does cargo affect trailer conditions, but equipment, air, water, pests, and even packaging debris can cause cross-contamination.

Assuming that these factors can make a food transport trailer unsanitary and unsafe for food, where do we start the process of mitigating these risks?

People and their Preferences

We all bring our whole selves to work, don’t we? Habits, experiences, training, education, and even our personalities can affect our work product.

So, without structure around our choices in how we do things, it is natural to rely on who we are and what we know to get our jobs done.

If people have sanitary preferences that don’t level with good science and food safety expectations, it’s okay if we’re talking about their own refrigerators or ice chests.

But we’re not. We’re talking about thousands of food transport trailers hauling food every day. These trailers may have been cleaned… or not, according to a ‘person’s’ own sanitary standards.

At Healthy Trailer, we have been impressed with the number of drivers who come in with good, hygienic expectations for their trailers. Many trucking companies have taken the high road in making sure that their trailers are cleaned and sanitized.

But…and you knew there would be a ‘but,’ right? It’s not a small number of drivers who show up at Healthy Trailer because a shipper rejected their equipment on unsanitary grounds.

Then there are the drivers who ask us to clean only the threshold and maybe a few feet into the trailer because “that’s all the cooler inspectors look at.”

If a driver or a trucking company has been given a protocol that only specifies that the trailer looks and smells clean, then the likelihood of pathogen contamination will be overlooked and/or ignored.

The ‘people preference’ will dictate the sanitary conditions of a trailer.

We have a ‘boots on the ground’ perspective based on what we see and hear. Also, because we’re the ‘go to’ resource for Salinas Valley loading facilities, we hear their stories as well. These tales of dirty trailers rarely work their way up into the sales and C-suite offices, but they are plentiful and real.

Ignoring the strong likelihood of people’s preferences that influence the trailer sanitation practices in your company will result in unsanitary, unsafe food transportation conditions.

Telltale signs of ‘preference-based’ protocols

It is accurate to say that even though FSMA transportation has been enforceable since 2017, it’s taken some time for industry members to accept that their transportation programs need to include food safety protocols.

The temperature control piece of FSMA transportation has been easier to adopt and implement because of the wide range of technological options available for monitoring the cold chain.

Trailer sanitation has been the barrier to safe food transportation becoming part of the food supply chain. There hasn’t been a ‘clean’ standard officially identified for trailer environments that would help people determine how to clean and when to clean and sanitize a trailer.

This brings us to ‘best practices’ as the accepted standard in food transportation. But we just reviewed the core problem of using best practices--they are preference-based. These are not science-informed practices; they are protocols based on what’s ‘best’ or preferred by people.

Who are these people? What roles in their companies do they play?

  • Are they reporting to a food safety or logistics manager?

  • Maybe they are employees tasked with a bunch of other trucking safety jobs?

  • Maybe they are in charge of reducing ‘external’ costs, like washouts.

These questions will help you better understand who is currently managing, directly or indirectly, your FSMA transportation compliance. Once you’ve identified who is making the washout decisions, then you can evaluate their choices.

But without specified protocols, you could end up managing a person’s preferences.

People in charge of approving washouts often select vendors based on the following:

  1. Personality type: Carefree or nitpicky (both can be bad).

  2. Cost: Cheapest is always best, right? (oh boy…scary)

  3. Availability: What tools are handy? Brooms, blowers, and hoses. (Maybe for a pre-clean?)

  4. Approval: Someone with influence who doesn’t understand FSMA compliance or contract requirements.

  5. Most expedient: It doesn’t have to be perfect, just convenient, and…looks and smells clean.

All of these possibilities can result in a cross-contaminated trailer, lost time when the trailer is rejected at the dock, fragile food safety culture, FSMA noncompliance, and weakened consumer confidence in your brand. All of which affect the financial strength of a company.

People make decisions based on personal preferences, and not always with science or logic. Without protocols in place you can't guarantee that they're going to choose trailer cleaning services that are in your best interest.

Protocols ‘sans’ People

The beauty of good food safety practices is that they give us both science and structure. Yes, people will be invaluable as we implement, but the guesswork and the questionable nature of preference-based protocols are greatly reduced.

Here are five tips you can use to ensure trailer sanitation is a priority in your organization:

  1. Use your customer contract and/or written specifications. Their preference matters the most.

  2. Rely on science-based protocols, not the ‘clean what you see/smell’ test. We have a good amount of scientific information about dangerous human pathogens, how and where they grow, and how to mitigate the risk of their presence. Use proven food safety science knowledge.

  3. Actually, practice the protocols. Implement specific and regular sanitation training and routines.

  4. Document the cleaning services and training you have completed with your employees. Record dates, prior cargo, washout vendors, and the training (dates/content)

  5. Actively manage your trailer sanitation program. You know this one, ‘Inspect what you expect.’ FSMA requires that you have a ‘competent supervisory person’ doing this

People are often the source of good and bad practices in our companies.

Their decisions about how to clean a trailer have more to do with their personal preferences than contamination risk reduction. That's why developing a strong set of protocols that your team can rely on for guidance when choosing vendors is so important.

Healthy Trailer is available not only to clean and sanitize your trailers but also to help you get this critical piece of the food supply chain FSMA compliant. Ask us questions, and if we don’t know the answer, we’ll find someone to help us all learn.

Our bi-weekly newsletter, specifically intended to help trucking companies, covers all sorts of issues that are FSMA transportation-related. You can subscribe here.

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