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#1 jfox1

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Posted 08 October 2018 - 05:00 PM

We have Canadian suppliers (grain) that are pushing back on our request for the previous commodity. They are saying that FSMA does not require them to provide this info. Can anyone help me out with whether or not this is true? 

 

Thank you! 



#2 Tony-C

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Posted 09 October 2018 - 03:14 AM

Hi jfox1,

 

Have they provided proof of cleaning prior to loading?

 

Also isn't this relevant:

 

§117.93   Warehousing and distribution.

Storage and transportation of food must be under conditions that will protect against allergen cross-contact and against biological, chemical (including radiological), and physical contamination of food, as well as against deterioration of the food and the container.

 

Kind regards,

 

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#3 Scampi

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Posted 09 October 2018 - 12:56 PM

B. Who is exempt from the requirements for the Sanitary Transportation Rule?

Non-covered businesses (see definition in Table 1) are not subject to the rule and therefore do not need to comply with the rule. In addition, shippers, receivers, loaders, or carriers subject to the Sanitary Transportation rule do not need to comply with the rule when they are engaged in the following transportation operations and activities.

Table 2--Exemptions for Part 1, Subpart O Exemption Conditions Transportation operations of food that is transshipped through the U.S. to another country 21 CFR 1.900(b)(1) Transportation operations of food that is imported for future export 21 CFR 1.900(b)(2) Transportation operations of food located in food facilities that are regulated exclusively, throughout the entire facility, by the U.S. Department of Agriculture under the Federal Meat Inspection Act, the Poultry Products Inspection Act, or the Egg Products Inspection Act 21 CFR 1.900(b)(3) Transportation activities performed by a farm 21 CFR 1.904 “Transportation operations” 2. A motor vehicle carrier that is not a shipper or receiver that has less than $27,500,000 in annual receipts. Transportation Any movement of food in by motor vehicle or rail vehicle in commerce within the United States. Contains Nonbinding Recommendations 9 Exemption Conditions Transportation of compressed food gases 21 CFR 1.904 “Transportation operations” Transportation of food contact substances 21 CFR 1.904 Food contact substances as defined in section 409(h) of the Federal Food, Drug, and Cosmetic Act Transportation of human food byproducts for use as animal food without further processing 21 CFR 1.904 “Transportation operations” See definition of “Transportation operations” Transportation of food that is completely enclosed by a container 21 CFR 1.904 “Transportation operations” Except a food that requires temperature control for safety Transportation of live food animals 21 CFR 1.904 “Transportation operations” Except molluscan shellfish

 

https://www.fda.gov/...n/UCM584453.pdf

 

I'm guessing one of the above exemptions is what they are talking about......assuming the grains are for further processing


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#4 jfox1

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Posted 09 October 2018 - 03:18 PM

Thank you. I am understanding that foreign shippers that arrange for transportation of food that is destined for the US are not subject to the rule but carriers and receivers of foreign goods in the US are. 

 

Basically we give the carriers and loaders our standards and request they meet them. If we become aware of conditions that could render the food unsafe we have to take action to make sure it doesn't make it to the marketplace and then reassess our suppliers. Obviously the FSVP applies to these situations. 

 

So for example:

 

We tell our supplier/loader/shipper our standards and unless we have reason to believe we need to audit them or reassess their procedures we are covering the requirements of the rule? 



#5 Scampi

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Posted 09 October 2018 - 03:37 PM

I would think you've got it covered.

 

There are a lot of grains moving back and forth between both countries so I would imagine they are all well versed in the requirements


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