How to get carriers to comply with Sanitary Transportation Rule?
Hello all,
How would you handle a situation where boxes of ingredient come in damaged, dirty, and nasty?
Aside from what we can see, which we fear would be only the 'tip of the iceberg,' we cannot guarantee that these boxes did not come into contact with various contaminants in sorting centers, on planes, trucks, etc.
In addition, some trucks have observably filthy floors, some floors wooden, some floors metal. Rarely are trucks swept completely clean.
We have really high standards, and unfortunately there are times when shipments arrive not to our liking. Our receiving department told me about times when we've seen visible footprints on top of boxes. Sometimes loads get stacked on top of other loads and this can cause wood fragments to get on everything underneath. I would say that there are times when our shipment has been downright desecrated by careless behavior.
Anyway, I know it's the law that shippers, loaders, and carriers must comply with the Sanitary Transportation Rule. They must use sanitary practices to ensure the safety of that food. How would we, as a practical matter, make shippers, loaders, and carriers comply with this requirement in light of what we have observed, as described above? Is a contract enough? It seems like so much depends on a person's attitude and how much they care, but sometimes people need to be forced into doing things responsibly.
We are manufacturing dietary supplements in the United States and comply with 21 CFR Part 111 and Part 117.
Thank you,
Matthew
reject all loads that do not comply and try and find other carriers that will. if shipping is up to the vendors, then yes, a contract stating clearly what is expected and that you will reject loads that do not comply
If they won't sign, find new suppliers that will
As Scampi, indicated in the above post, reject all damaged boxes on receiving. If they dont comply, let them know that your company will be looking out for some other/new suppliers.
Taking pictures, on receiving, of the damaged boxes or boxes with footprints on the boxes is a good way to communicate to your vendor and make them understand of your rejection.
Some (bigger) companies have this written in their Supplier Expectations Manual or in the contract with the suppliers to deliver goods in sanitary conditions.
My reply is more of a question to the original post. Is there a secondary packaging for the item, itself?
Has data been presented to the vendor to show the impact of their non-compliance service? This would be helpful when presenting a platform to pull business, especially if there is cost associated with this issue. Like FSQA mentioned, I would ensure that the expectations are well written in a Supplier Manual or agreement.
I agree with Scampi.
Considering that your personnel are actually inspecting the insides of the incoming trailers and actually documenting the sub-standard conditions of same - you are setting yourself up when you document your inspections and then go against your own standards and accept the delivery.
No accepting deliveries because of terrible conditions for the delivery vehicle gets documented and you notify your shipper of the situation. Get a sanitary contract together and if they can't comply get new suppliers/new transporters.
Yes mec862, the secondary packaging is typically an inner plastic liner--sometimes multiple layers of plastic liner.
We actually reject parts of shipments for non-conformances frequently, so yes, this information does go back to the supplier and we are sometimes filing shipping claims.
Agree with all of the comments. Reject the load and file a complaint with your supplier and/or trucking companies. Take pictures PRIOR to unloading the truck so you have good evidence that you didn't cause the damage.
We have a clean transport agreement we had all of our approved carriers sign.
Upon arrival, whether the truck will be delivering materials or shipping finished product to another location, our Shipping/Receiving personnel inspect the trailer before the truck is even allowed to back it into our docks. They record the condition of the trailer on a check sheet, and if there's a violation, personnel are instructed to take pictures and inform the Shipping Dept Supervisor, who rejects the truck. If we reject a truck, the cost is the responsibility of the carrier.
Once the trailer is accepted, we allow them to back into the dock. We provide a spotlight that personnel use to further inspect the trailer before finally loading/unloading.
Since putting the agreement in place, we haven't had many problems.
Unfortunately, the situation described doesn't really fall under the sanitary transportation rule and your only recourse is to reject loads based on your contract with carriers. Those new rules will only be enforced / applied to foods that are exposed (not completely enclosed) or foods that require temperature control for safety. Relying on regulations is no way to ensure safety anyway. The rules are the minimum. You have to employ training and economic consequences for failures.