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Refrigerated vs Dry Food Transport

FSMA Food Transport Refrigerated Dry

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#1 Louie S.

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Posted 23 March 2018 - 03:19 PM

Hello from Austin!  I know this is a long post but I really want to know what you guys think....

 

OK, so yesterday we had one of our local transportation brokers come out to talk to us about FDA's Sanitary Food Transportation rules and what they are doing about it.  Basically, she gave us a talk about how one of their senior reps told her that since they only do dry loads that they are exempt.  Gave me some typed up Q&A that she made for us (big font, lots of bold) and told me that she had done her research.  That only refrigerated trucks were subject to this ruling.  

 

Of course I didn't buy what she was selling.

 

I had already done some webinars/research and from what I understand this is for ANY food transport method (unless you're exempt like Milk tankers).  I fully understand that for refrigerated transport this ruling weighs a bit heavier but don't tell me that this does not apply to you! ::breath::

 

We use transportation brokers to schedule our LTL pickups which is primarily for dry products.  We have always asked for our products to be transported in clean, good repair, trucks.  No chemical hazards are allowed to be transported in the same truck.  We also ask them to not carry any open products that might cause some cross-contamination.  We have never had any issues with them not following our requests.

 

For anyone that is either in food transport or deals with transport brokers, my question as a receiver is what should I ask from them to be compliant with this ruling?  We can't do contracts because we do spot purchases and do not have trucks coming here daily.  Or is what we are already requesting on the BOL enough?  Possibly some sort of letter of guarantee with our requests on it?

 

Or is it just me being annoyed by her trying to pull a fast one??  :yeahrite:

 

- Louie



#2 Scampi

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Posted 23 March 2018 - 04:41 PM

quoted from https://www.fda.gov/...A/ucm383763.htm Exempt from the Rule

  • Shippers, receivers, or carriers engaged in food transportation operations that have less than $500,000 in average annual revenue
  • Transportation activities performed by a farm
  • Transportation of food that is transshipped through the United States to another country
  • Transportation of food that is imported for future export and that is neither consumed or distributed in the United States
  • Transportation of compressed food gases (e.g. carbon dioxide, nitrogen or oxygen authorized for use in food and beverage products), and food contact substances
  • Transportation of human food byproducts transported for use as animal food without further processing
  • Transportation of food that is completely enclosed by a container except a food that requires temperature control for safety  Maybe she was right............perhaps this is the exclusion she was referring too
  • Transportation of live food animals, except molluscan shellfish

Because we always have is never an appropriate response!


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#3 Louie S.

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Posted 23 March 2018 - 05:26 PM

quoted from https://www.fda.gov/...A/ucm383763.htm Exempt from the Rule

  • Shippers, receivers, or carriers engaged in food transportation operations that have less than $500,000 in average annual revenue
  • Transportation activities performed by a farm
  • Transportation of food that is transshipped through the United States to another country
  • Transportation of food that is imported for future export and that is neither consumed or distributed in the United States
  • Transportation of compressed food gases (e.g. carbon dioxide, nitrogen or oxygen authorized for use in food and beverage products), and food contact substances
  • Transportation of human food byproducts transported for use as animal food without further processing
  • Transportation of food that is completely enclosed by a container except a food that requires temperature control for safety  Maybe she was right............perhaps this is the exclusion she was referring too
  • Transportation of live food animals, except molluscan shellfish

 

 

She did not specify exactly where she had received her info from but I did see this exemption list.  So possibly just basic food safety protocols?? 

 

My "overly cautious thinking" brain did not accept this list because "How can FDA not include my product? IT'S A TRAP!"



#4 Scampi

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Posted 23 March 2018 - 05:37 PM

LOL!!!!!!  I love that, shows how much faith we all have in the feds!!!  

 

hopefully (she types while grinning/groaning) they have done a risk based look at transportation and realized that dry shelf stable non refrigerated products are not likely to be contaminated by other food stuffs or even a crate full of nails for that matter, as long as they are enclosed in some sort of packaging.

 

We are all by our nature inclined to think its a TRAP!!!!!!!

 

where i am now runs 50% organic and the new Canadian rules (that should have been out 2 years ago and now we are waiting on pins and needles anyday now) say that ORGANIC conveyors need a licence! How the H E double hockey sticks am I going to get anybody to haul my stuff (shelf stable non refrigerator) across the damn country who has got a license.............particularly when the non-organic trucking company doesn't need one!!!!!!

 

 

In my next life i'm going to be a lobbyist!!!!   or maybe a cat-they have it pretty sweet


Because we always have is never an appropriate response!


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#5 FurFarmandFork

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Posted 23 March 2018 - 06:15 PM

Agree with the above, ship bottled water here and ran into the same problem, sealed, shelf-stable products are exempt from the rule.

 

Your best defense are the following older citations for enforcing sanitary transport for your products:

 
21 CFR 110.93
 
Storage and transportation of finished food shall be under conditions that will protect food against physical, chemical, and microbial contamination as well as against deterioration of the food and the container.
 

 

 

Pieces of this guidance on FSTA that apply:

 


In our effort to assist the food transport industry in preventing food safety problems during transport while we are implementing the 2005 SFTA, we want them to be aware of the following problem areas where food may be at risk for physical, chemical, or biological contamination during food transport:
 
  • Poor pest control in transportation units (or storage facilities used during transport) FF&F: Which would include gaps/access that permit pests to interact with product while material is transported or stopped.
  • Inadequate preventive maintenance for transportation units (or storage facilities used during transport),  resulting in roof leaks, gaps in doors, and dripping condensation or ice accumulations; FF&F:  gaps unacceptable
  • Inadequate policies for the safe and/or secure transport (or storage during transport) of foods, e.g., lack of or improper use of security seals; FF&F: You can't lock it up, food defense issue

Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.

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#6 Maggie White

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Posted 10 May 2018 - 05:58 PM

In dealing directly with the carrier you can ask to see a copy of their Food Safety Protocol via email. You can also ask to see their Trailer Inspection sheet. As a shipper, this is what I would do. If you are using the services of a load broker/freight forwarder would you not request evidence that the carriers he is using have Food Safety Protocols in place? If I am not mistaken, under FSMA (and the Safe Food for Canadians Act) Load Brokers are regarded as Shippers and assume the responsibility for Food Safety the same as the Shipper would be.







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