SQF 13.6.3.3: Food Packaging Transportation - Sealed Trailers
I used to run finished food goods LTL without any other option. I had service/contractual agreements from the trucking company that once loaded, the integrity of my product was their responsibility. That worked for me Notice the code says "or system" that allows for situations just like yours. Basically you cannot ignore transportation risks because of LTL, but you can provide an alternative to seals/locks
I have quite a few standards, depending on product grade, that I have to meet here.
NSF had a similar requirement for water grade product. After risk analysis, I determined the risk in shipping was if a product was tampered with (opened/resealed) during transit. We put in a system that all NSF grade product must be sealed with tamper evident tape (supersacks, 50lb bags, LTL, full load) and alerted our product managers to pass that info along to the purchasers (customers) of that grade of product, so they are checking for the intact tape on their end of the delivery. That satisfied our auditor in that instance.
Note: Water grade NSF product additives are different than SQF (or GFSI) standards. But it might be worth looking into.
most will concentrate on the seals first - but concentrate in this area - other acceptable device or system as agreed upon by the carrier and customer.
you will need to meet with the carriers and inquire as to how your loads are protected, protection would also include transfer points as well as getting an understanding on how drivers and helpers are training on loads that were there is or can be a food safety impact.
i was pleasantly surprized to see a number of carrier reps at a recent state food protectors organization meeting that really were very keen on food safety in handling their clients loads.
Our (SQF Food Packaging Manufacturer - paperboard packaging) system requires seals for incoming raw materials and only full truckloads outbound. Partials are all stated to be the carrier's responsibility from the time they take possession with verification sign off from the driver as to the condition of the product received. In our contracts with carriers safe handling is outlined and required. Trailer inspections incoming and outgoing etc... Our loads are all stretch wrapped so that is a visual gauge to ensure there has been no tampering and condition is verified by the end user / customer / consumer. FDA is only referenced for LOG's to customers and from suppliers.