5 replies to this topic

[khennen]

We are a manufacturer of printed polyethylene bags and films for direct contact food packaging. The SQF Code Edition 9 now has a requirement under 13.6.3.3: Loading, Transport, and Unloading Practices that states: Vehicles (e.g. semi-trucks, trailers, vans, containers) used for transporting food sector packaging from the site shall be secured from tampering using a seal or other acceptable device or system as agreed upon by the carrier and customer. According to the FDA's Final Rule on Sanitary Transportation of Human and Animal Food: The definition of “transportation operations” has been changed to exclude: Transport of food contact substances, which include coatings, plastics, paper, adhesives, as well as colorants, antimicrobials, and antioxidants found in packaging. Virtually all of our shipments are LTL and adding seals is not only impractical but would be very cost prohibitive. I'm interested in the opinions of the group as to the use of "other acceptable device or system". Is there a way to demonstrate compliance by carrier/customer agreements or some other form of internal documentation?

[Scampi]

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

[TimG]

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.

[SQFconsultant]

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.

[Hoosiersmoker]

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.

[mikeq]

We are a secondary box manufacturing company.  Our glue totes, ink containers, coating containers, are all sealed.  The incoming trailer that delivers these containers do not use seals.  We inspect the individual tote or container to make sure that the seal is not broken.  How 13.6.3.3 interpret this?  

 

Thanks,