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Sanitary Transportation of Human and Animal Food

Sample of a procedure

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#1 HokeyPokey

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Posted 26 August 2019 - 07:11 PM

I am writing our sanitary transportation procedure.  Need help on what goes in the procedure. 

 

Thanks 



#2 MsMars

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Posted 26 August 2019 - 07:18 PM

Product? Process?



#3 HokeyPokey

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Posted 26 August 2019 - 07:29 PM

Ice cream Plant. 

 

Process? - We receive ingredients and shipped finished product. 



#4 LostMyMind

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Posted 27 August 2019 - 12:05 PM

The rule applies to four generic groups (ignoring all of the exceptions that exist with any of these rules): shippers, receivers, loaders and carriers.  The bulk of the responsibility is on the carriers.  IMO, from what I've read, as a producer, you would interact with this rule:

  1. When you receive product
  2. When you load product
  3. Possibly within your process to select shippers (we don't manage that ourselves, so I didn't research, but I know that the drivers, etc. have to be trained, so you would want language in your contracts with them about that possibly).

For receiving, our existing inspection processes already ensured that shipments coming in were transported correctly, so I didn't change anything.  If you have a GFSI audit, you are likely already covered.

 

For loading product, I made the following changes to our existing processes:

  1. Added language to our driver's log to ensure that they acknowledge their responsibility under the rule:
    1. FSMA Regulations: By signing below, you are signifying that you are in complete accordance with all applicable food safety carrier regulations surrounding the most current version of FDA’s FSMA Sanitary Transportation of Human and Animal Food rule. 
  2. Adjusted the language on that same drivers log around the temp that the driver lists for their trailer making it more of a "certification" of the temp.
  3. Adapted our existing Trailer Inspection processes to reflect the rule's language.  I attached a sample of that for you.
  4. Adapted the language that is on our load sheets forcing the loader to acknowledge the rule and confirming that they completed the required inspections.
    1. By signing below, you are certifying that the trailer you are loading is safe to transport food (clean, sanitary, free of pest evidence, odors, and in good physical condition).  If refrigeration is required, you are certifying that the trailer's temperature is already lowered by pre-cooling and that the refrigeration system appears to be operational.  Please consult the loader’s work instructions or your manager if you have any questions.
  5. We already keep both documents, so no changes to our paperwork retention processes was necessary.
IMO, this is a rule that the Feds wanted to do more with, but realized quickly that shipping is much more complicated than they imagined and so they backed off on their original vision.
 
Some resources:
Carrier Training (I took so I would have a better idea of the rule): https://www.fda.gov/...nimal-food-rule
 
I hope that this helps somehow.
 
Good luck,
Todd

 

 

 

 



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#5 LostMyMind

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Posted 27 August 2019 - 12:28 PM

Not sure why the file didn't load.  Here you go...

 

Attached File  LoaderExample.docx   24.47KB   13 downloads


Edited by tsebring, 27 August 2019 - 12:29 PM.


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