5 replies to this topic

[The Food Scientist]

Hi everyone! So a potential carrier has asked us to fill out an application for them and this was one of the questions they asked and I am not really sure what the perfect answer would be:

 

Please describe any FSMA protocols that you have in place so that TQL, as a non-asset based broker, can accurately communicate them to the third-party motor carrier:*

 

Can anyone assist?

 

Thank you :)

[Kerry785]

For us we can only ship on trucks that have food grade materials and no chemicals on board. No tree nuts or peanuts (we are a nut allergen free facility/food). Is it required to be chilled? Trailer requirements: no obvious damage, clean, free of odors, no obvious leaks, etc.

[The Food Scientist]

For us we can only ship on trucks that have food grade materials and no chemicals on board. No tree nuts or peanuts (we are a nut allergen free facility/food). Is it required to be chilled? Trailer requirements: no obvious damage, clean, free of odors, no obvious leaks, etc.

 

What do you mean trucks that have food grade materials? Like what for example? 

[SQFconsultant]

Our SQF clients require that carriers provide documentation on driver training in the area of food safety.

 

For trailers - not dirty, no damage, refrigerator readouts available from time of loading to time of delivery, carriers can only carry food and food grade materials for humans. 

 

There are some other requirements such as finding our where your load will be transported (as in is the load going to be transferred to a DC in-line and then re-loaded) to or will it stay in that one trailer all the way to destination and will the same carrier personnel be the ones that deliver to your customer.

 

We tracked a trucker one day that picked up a load from a client and they were supposed to leave it intact  on the same trailer, and if rigs changed it would be same company and same company drivers.

 

Oh, no - that did not work out....

 

The load was delivered to an in-line DC, and then transferred to different company with different drivers and then 50 miles before destination it was delivered to another DC and picked up by the same company -- so that when they did the delivery it appears to have never changed hands.

 

Got to watch your carriers like a hawk.

 

One client put a go pro camera on a load - interesting footage.

[Kerry785]

Food grade for human consumption - lubricants that are food grade, other food ingredients such as flour, sugar, etc. We take all the stress out and everything in and out is FOB.

 

[LostMyMind]

The bulk of the responsibilities on the sanitary transportation rule is on the carriers and the shippers.  I think the first thing is to understand who you are under FSMA's rule.  Sounds like perhaps both the shipper and the loader. 

 

As the loader, you (as others have pointed out) are responsible for ensuring that the vehicle is clean, not-smelly, etc. and to document those inspections.  You also own any specific items like verifying trailer temps, etc. that might apply based upon your HACCP analysis.  Someone else handles the shipper function for us, so I am not very familiar with that part of the rule, but you can refer to the info below for more details on that responsibility.

 

If I were the shipper, then personally, I look at this a little differently and would want the broker to provide assurance that their carriers and drivers will be in compliance with FSMA regulations.  It's a liability concern to me if you are coordinating your own loads.  These carriers are all supposed to have had their drivers trained and be following certain rules (and we know how likely that is to have occurred).    

 

For the loader responsibilities, our driver check in sheet requires the driver to:

 

1. Documenting what temp the trailer is set to:
2. Certify that their trailer is "Clean, Sanitary and Odor Free"
3. Provide their signature agreeing to the following statement:
   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.
4. Provide their signature agreeing to the following statement:
   1. "By signing below, you are agreeing to abide by Company's Food Safety & Food Defense Procedural Agreement which is posted for your convenience on the wall of the shipping office.  You further acknowledge that your access to our facility is restricted to X and Y locations."

We require our loaders to check the temps, the trailer conditions, and verify any other pick ups/existing loads and that is documented (of course).

 

Here's some info that might help:

 

The Transportation rule itself can be found here:

https://www.fda.gov/...and-animal-food

 

Here's a fact sheet that might be helpful:

https://www.fda.gov/.../97317/download

 

Carrier Training (that helps you understand what they are supposed to do): https://www.fda.gov/...nimal-food-rule

 

The Regs: https://www.ecfr.gov....1.1.o&rgn=div6

 

 

The FSMA specific loader language is below.

 

( c ) Requirements applicable to loaders engaged in transportation operations. (1) Before loading food not completely enclosed by a container onto a vehicle or into transportation equipment the loader must determine, considering, as appropriate, specifications provided by the shipper in accordance with paragraph (b)(1) of this section, that the vehicle or transportation equipment is in appropriate sanitary condition for the transport of the food, e.g., it is in adequate physical condition, and free of visible evidence of pest infestation and previous cargo that could cause the food to become unsafe during transportation. This may be accomplished by any appropriate means.

 

( 2 ) Before loading food that requires temperature control for safety, the loader must verify, considering, as appropriate, specifications provided by the shipper in accordance with paragraph (b)(2) of this section, that each mechanically refrigerated cold storage compartment or container is adequately prepared for the transportation of such food, including that it has been properly pre-cooled, if necessary, and meets other sanitary conditions for food transportation.

 

 

A lot of info, but perhaps some of it will be of help.

 

Good luck,

Todd

Edited by tsebring, 06 November 2019 - 12:41 PM.