Does anyone have a sanitation program for trailers?

Hello!

Does anyone have a sanitation program for trailers? We are a storage and disctribution center, and our customer (the manufacturer of dry pet food) is asking us for sanitation records.

We do not own or lease the trailers. They are leased to our customer. Who is then responsible for the sanitation of the trailers?

Would appreciate any help!

I found this under FSMA

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

• Another change is particularly important to rail carriers. Commenters raised concerns that rail operators often do not own, prepare or operate equipment, e.g, refrigeration units, in the railcars they transport, and do not have the ability to ensure that certain requirements such as temperature control and sanitary conditions, are met. The shipper or loader, and not the rail carrier, has generally assumed responsibilities, such as inspecting a railcar, to ensure that it is suitable. Shippers will continue to hold primary responsibility for sanitary conditions of transport under this rule unless the carrier has entered into a written agreement with the shipper to assume this responsibility.
  • By contrast, motor carriers generally own their vehicles and are directly involved with sanitation during transportation operations

Primary responsibility for determining appropriate transportation operations now rests with the shipper, who may rely on contractual agreements to assign some of these responsibilities to other parties.

• Shippers must develop and implement written procedures to ensure that equipment and vehicles are in appropriate sanitary condition.
• Shippers of food transported in bulk must develop and implement written procedures to ensure that a previous cargo does not make food unsafe.
• And shippers of food that require temperature control for safety must also develop and implement written procedures to ensure that food is transported under adequate temperature control.

Since customer is leasing the trailers that your facility loads onto it is the customer that is responsible for ensuring the trailers are clean, pest & Odor free, etc.

However, it is your responsibility to inspect each trailer prior to loading for the exact same things.

There are two options:

If the trailer is in need of Sanitation services you can:

A. Refuse to load, turn the transport away and return after the trailer has undergone a sanitation session.

B. Clean the trailer with your own personnel, load the trailer and send an invoice to the customer for the cleaning.

C. Clean the trailer with your own personnel, load the trailer and absord the associated costs.

There is of course a catch with these - if a pest issue, rats, mice, etc then the trailer is refused - with customer contact for remedy

For our clients most go with C.

A Food Safety Auditor/Inspector is not going to care that a trailer is leased by a customer, I actually had facility personnel inform me that if a trailer was not their own that while they "might inspect it and note any issues" that it was not their responsibility to ensure the trailer was clean.

That didn't exactly fly to well.

Thank you! 

We do inspect trailers and will sweep them out if needed.

This was really helpful.

To appease your customer, you can show them your loading/unloading procedures that should specify the trailer inspection that occurs, and how you'll either sweep the trailer for debris or reject a trailer if too unsanitary (ex: maybe a 3rd party trucker shows up with gallons of motor oil spilled all over the floor).  You could forward them a few inspection forms that (hopefully) capture whether the trailer was clean when you loaded it.

That we do have - maybe even take pictures of rejected trailer - thank you!

Hi ahinojosa,

To add to Glenn’s post, I would like to see the responsibilities clarified in your contractual arrangements with your customer. This avoids confusion.

Your responsibility is clearly to inspect Trailers used for transporting food prior to loading to ensure they are clean, in good repair, suitable for the purpose, and free from odors or other conditions that may impact negatively on the product.

The sanitation aspect and records need to clarified with your customer or as Glenn says you could just get on with cleaning each trailer and maintain records of sanitation yourselves.

Kind regards,

Tony

Hallo.

Our international Association ENFIT - Supply Chain Safety, (www.enfit.eu) has developed international standards for the cleaning of road tankers, silo trailer, tank-container, IBC, refrigerated trucks and vessels. 

If you are interessted, we can talk about how we can help you. 

my email adress: philipowski@enfit.eu

or Vladimir Surcinski: surcisnki@enfit.eu

Best regards Hans-Dieter Philipowski
President ENFIT