Wisconsin Potato and Vegetable Growers Association

Food Safety Modernization Act Requirements for Transportation Divisions

Under FSMA came specific adjustments to WPVGA’s Food Safety classes lineup, and now there may be requirements for certain transportation divisions as well.

The FSMA regulation that goes into effect for transportation companies with over 500 employees on April 1, 2017 and for the remainder of companies on April 1, 2018. The Wisconsin Motor Carriers Association (WMCA) recently held a seminar on this topic; another one could be held in the near future.

According to Thomas E. Bray, Lead Transportation Editor at J. J. Keller & Associates, Inc., here are the basics of the rule:

“All food chain members (shippers, loaders, and carriers) are expected to follow known and recognized practices and best practices to keep food safe (free of contamination and under temperature control when required). Vehicles must be designed for the purpose, cleanable, clean and sanitary, maintained, stored in such a way as to prevent the harboring of pests (insects and animals), and inspected before use. Generally, under the rule the shipper is the party that establishes the standards, and carriers must meet them when it comes to vehicles and equipment (totes, pumps, hoses, etc., that belong to the carrier).

The shipper and carrier must have measures in place to prevent contamination during loading, transport, and unloading, such as inspecting and cleaning the vehicle and equipment, requiring hand washing, hair nets, beard nets, and segregation of products (protecting food from other food, past cargos, or non-food products that could lead to contamination).

If the shipment requires temperature control, the shipper is to provide the required temperature range and the carrier must see to it that it is maintained. Loaders must confirm that the temperature control system is able to achieve the required temperature (vehicle must be precooled to the correct temperature…this means the driver needs to precool the vehicle). If requested, the carrier will need to provide proof that the temperature was maintained during the movement (system records, tattle-tale, driver hand-written temperature log, etc.).

If the shipment will be moving as a bulk shipment (the product will be in direct contact with the inside of the vehicle), then the carrier must be prepared to provide information on the last shipment and last washout/cleanout to the shipper.

As far as specific responsibilities:
Shippers must:

  • Have written agreements with carriers covering any responsibilities they are assigning to the carrier (equipment specifications, cleaning and sanitizing instructions/requirements, temperature control monitoring and tracking, etc.)
  • Make sure the vehicle meets the shipper’s specifications and meets the cleaning and sanitizing standards the shipper has established
  • Make sure the vehicle is at operating temperature before loading temperature controlled shipments
  •  Develop written procedures covering:
    o Making sure vehicles are clean and sanitary
    o Verifying that a previous cargo will not make the vehicle unsafe for the product
    o Ensuring that the food is transported under adequate temperature control

Loaders must determine:

  • If the vehicle meets the shipper’s specifications
  • That the vehicle or transportation equipment is in appropriate sanitary condition based on the shipper’s standards
  • That the vehicle is free of visible evidence of pest infestation, contamination, and remains of a previous cargo that could cause the food to become unsafe
  • That the cargo area has been properly pre-cooled if temperature control is required
  • If there are any other condition present that may lead to food becoming unsafe

Carriers must follow whatever requirements the shipper places upon then via a written agreement and have written policies covering:

  • Cleaning, sanitizing, and inspecting vehicles and equipment
  • Monitoring and recording temperatures on temperature controlled shipments
  • Maintaining and providing records of most-recent cargo and washout/cleanout

If anyone involved in the movement (shipper, loader, carrier, receiver) becomes aware of a situation that could potentially have made food unsafe (exposure to contamination or temperature abuse), they must notify the others and a qualified expert must evaluate the food before it can be distributed or sold as food.

Carriers must train drivers on:

  • An awareness of potential food safety problems that may occur during transport and how to prevent them
  • Basic food safety/sanitary practices
  • The requirements of the food safety rules

Note: these rules do not apply to all food shipments. They apply to food that is moving in bulk (the product is in contact with the inside of the vehicle), food that is not fully contained within its packaging (food in open totes, vented boxes, open boxes, etc.), and food that requires temperature control when transported.

Large entities (companies that have more than $27.5 million in annual receipts) must comply as of April 6, 2017, and small entities (under $27.5 million in annual receipts) have until April 6, 2018 to comply. However, if a small entity carrier is working with a large entity shipper, the shipper can require the carrier to comply when the shipper has to (as of April 6, 2017).”

If you have questions about the rule, you may contact Thomas Bray at J. J. Keller & Associates, Inc. by email ([email protected]) or by phone (800-558-5011 x-2863). If you would like additional information regarding an upcoming compliance class through the Wisconsin Motor Carriers Association, or would like to register for a class, please visit www.witruck.org. The WMCA offers both member and non-member rates for the class. If you have additional questions regarding the class, you can contact Susan Webb at the WMCA (608-833-8200 ext 12).

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