It’s Not About You
The Role of Social Responsibility in FSMA Transportation
More than once last week I heard people commenting on the fact that St. Patrick’s Day was odd and sort of lonely. Will we be together for Easter? Social distancing is now our new norm until COVID-19 is under control.
How did this event get so out of control? Who didn’t wash their hands or cover their mouth when they coughed or sneezed? It doesn’t matter now. We the People, in our interactions with the Public, are now missing much anticipated celebrations, we’re separated from loved ones, we can’t meet up with our colleagues, customers and suppliers, and the shelves at the grocery store are empty.
The obligation of cleaning and following proven health habits starts with an individual. Or an individual family, or company, or organization. But it’s not really about the ‘one.’ Sanitation is about the effect of the ‘one’ on the many. One wrong, unhealthy choice can extend, or maybe the better word is ‘explode’,into something that has far reaching and devastating results. Shelter in place?
Here’s a simple, true story of how someone’s neglect affects an entire neighborhood.
A few years ago my parents’ home and many others near it were overrun with black rats. The Rattus rattus is an agile, large (as in 12 to 14 inches,) and often dark pest that is known for its invasiveness and tendency to cause vast damage to trees, crops, some bird species, and homes. They are creepy and disgusting.
When I saw the first one deftly scurry across the telephone lines, I thought it was a small cat. Of course my willingness to sit outside and enjoy the evenings on the patio diminished with each rat sighting. How could vermin like that end up in a rather upscale neighborhood?
It turns out that a neighbor’s empty house down the street had fruit trees in the back yard that were flourishing during the summer season. Because no one was home, or at least no one was around to pick up the ripe and rotting fruit, the rats were feasting, and multiplying at a rapid rate. After an aggressive rat catching and destroying effort, along with the elimination of the fruit trees, this obnoxious and dangerous health hazard was finally brought under control.
This is a sanitation story. Check out most definitions of sanitation and you will see that at its core is the preservation of the public’s health.
Sanitation is an obligation that all of us living in society owe our fellow citizens. But because much of our personal sanitation and hygiene is private, it’s simple to understand why communities may not know that one of its citizens is creating or contributing to a serious public health problem.
Sanitation is a private responsibility that has public consequences.
Before I start my argument about why companies involved in food transportation should pay attention to trailer sanitation, I want to be very clear about what I am NOT saying.
There has been no evidence found that links COVID 19 to food, food packaging, handlers, or food transport trailers. If you have not done so already, please refer to the FDA’s resource page to learn the critical facts about COVID 19 and its relation to food and the food industry.
My discussion is about behavior, about choices made by the few that can affect the masses.
Healthy Trailer is in the sanitation business. In fact, our site operations are called Trailer Sanitation Stations. We know that consumers expect that their food is being transported in clean and sanitary trailers. And after two years of cleaning trailers and talking to people in the industry, we know a few things about the unsanitary conditions of food transport trailers.
Are consumers getting what they are expecting? Are food transportation companies practicing food sanitation in their trailers?
What is food sanitation?
Ronald Schmidt, professor and food science Extension specialist from the University of Florida wrote this definition of food sanitation:
A three-word definition of Food Sanitation is protection from contamination. With this in mind, all functions and operations must be included in a sanitation program. All food products must be protected from contamination from receiving (and before) through distribution. Sanitation is a dynamic and ongoing function and cannot be sporadic or something that can be turned on once a day, once a week, etc. Therefore, another definition could be: "sanitation is a way of life".1
Protection from contamination. And what Mr. Schmidt states so clearly is that ‘one and done’ is not the right approach to good sanitation.
Not only in the field, or the plant, but through distribution. That means during transportation. Field TO Fork, Farm TO Table, whatever we choose to name the step between the producer and the end receiver, we are all talking about the same thing--namely, the means of transporting the food from one end of the supply chain to the other end.
The issue of what actually constitutes a ‘clean and sanitary’ trailer environment envisioned and required in FSMA has been a subject of much debate. There is not an abundance of scientific information available specific to trailers. Healthy Trailer is working on getting that information for all of us.
But in the absence of data, should the food transport industry rely on the prevailing best practice standard, which is ‘If you can’t see it or smell it, it’s not there’?
We are gaining important knowledge through observation and data collection. But in the meantime, we do have something sort of ‘old fashioned’ that should be relevant in today’s policies regarding trailer sanitation.
It’s called common sense.
From what we have learned at Healthy Trailer, food products are often loaded and transported in unsanitary trailers. Each driver that skips the clean, each shipper or buyer who declines to specify a clean trailer protocol, and each receiving crew who fails to note the condition of a dirty trailer on arrival, all are ignoring what common sense should tell them--don’t assume the trailer is contamination free.
What are some of the common sense proactive, preventative sanitation measures:
Know the trailer’s prior cargo;
Know when the trailer was last cleaned;
Don’t rely on brooming or blowing to clear out debris;
Don’t use washout facilities that only hose down sections and/or randomly apply sanitizer;
Clean your load locks;
Organize your pick up schedule to allow for proper sanitation;
Remove stickers, labels and other material from the walls;
Always check with your customer about their specified sanitation requirements; and
Keep your doors closed while you are waiting for a load.
Develop, implement and maintain a sanitation schedule for your equipment-document;
Check your transportation contracts for customer sanitation requirements;
Train your drivers and document the training;
Support your drivers’ efforts to be FSMA clean;
Communicate with your suppliers and customers about unsanitary conditions that may be negatively impacting your operations;
Develop, implement and maintain sanitary procedures for home and on the road-document; and
Pre authorize sanitation stations for your drivers to encourage proper sanitation
For shippers, loaders, and receivers:
Realize that if someone in this FSMA stakeholder group does not specify sanitation standards, it very likely is not happening;
Use known and proven food safety strategies in your transportation plans that you already have developed, implemented, monitored and are documenting
Communicate with carriers and drivers about your sanitation specifications;
Don’t rely on contract language to verify that your specifications are being practiced;
Support your carriers and their drivers in their correct sanitation decisions and actions;
Don’t ignore a problem-manage it according to your specifications-document;
We are witnessing (and unfortunately now participating in) what happens when someone disregards their personal obligation to protect the public. Common sense would have been to wash hands, cover mouths, and don’t be around people when you’re sick.
The same logic applies to proper and necessary trailer sanitation. FSMA makes it a legal obligation. But regulations almost become secondary in comparison to meeting our social responsibility in providing only safe food.
Keeping people safe, whether privately or at work, often happens one decision at a time. As we all make our food transportation decisions, let’s remember that all over the world people are depending on us to use our common sense and do the right thing.
1. Ronald H. Schmit, professor and food science Extension specialist, Food Science and Human Nutrition Department; UF/IFAS Extension, Gainesville, FL. This statement is from Basic Elements of a Sanitation Program for Food Processing and Food Handling.