Food Defense and LTL Shipments 2.7.1

Hello all, 

We finished our very first onsite audit a little over a week ago, and one of our Corrective Actions is on Food Defense for Finished Product once it leaves the building. 

We had in our policy to only use approved Freight carriers, but that was deemed unacceptable. 

We are a bottled water and bottled beverage facility, and 90% of our product ships LTL Carriers.   Yes we put a Lock on the LTL Truck after we load it, ( which I still do not agree with, since they take it off at the next stop) and we really only do use certain carriers.  

Because we pay the freight, the product is required to be "controlled" until the customer takes possession and LTL is not considered controlled once it leaves our hands. 

Can anyone offer any assistance here?.  Our beverages are in plastic bottles, with Tamper Evident Caps, shrink wrapped by the case, and the pallet is also shrink wrapped 8 times with a sheet of cardboard on top.   

It would be evident it was tampered with by the packaging.   And this was deemed not sufficient. 

Can anyone offer any guidance? I am stuck on what else to do here.  We are considering challenging the CAR. 

Food Defense isn't just tampering with the bottles in this case, it could be the theft of the product and re-sale with different labels on (not so bad for water, but can be deadly for something with allergens in).

Your biggest problem here is the LTL shipping. Regardless of if you lock the doors, this will be unlocked at the next collection point so the vehicle can be loaded with the next collection. This is the point in the process where the Food Defence falls down.

I see two possible options:

1. Stop using LTL and use your own transport to deliver direct to your end customer. This removes the risk and allows you to deliver safe product in full. What happens after this point is not your concern as it has hit the end customer from a Food Defence point. - This is likely nonviable and expensive.

2. You need to strengthen up your due diligence for the Food Defense post despatch. You know that the truck is going to be making multiple collections, and these will not be the exact same day-in day-out. But you can do a few things to help you.

• Audit the LTL company - request to accompany a driver on the entire route of the product from collection at your end to the final delivery point.
• Ask to see training records of the driver(s) in Food Defence.
• Set out some basic rules you would expect the driver to follow at each pick-up regarding ensuring that the security of the product is maintained at all times.

There are so many variables though with LTL transport that it is going to be difficult to pass the Food Defence with it. Such as:

• Will the driver be asked to hand over their keys to a company whilst awaiting loading? (we ask drivers to hand over their keys and wait in a dedicated area for Health & Safety purposes).
• Will the driver always be present when the vehicle is loaded at each point following on from the collection of your product?
• What is the intake procedure at the final customer?

I would look at what is the maximum you can do that is reasonably practicable to do. We can never account for every scenario, but auditing your LTL Carriers and giving them specific Food Defence instructions would be the best start.

I will give you the other side of this coin.....Challenge the CAR

It is unacceptable for a GFSI scheme to force you int bankruptcy by switching from LTL to full loads, even if you're only moving 8 skids for the sake of having a trailer that doesn't open until it arrives at it's final destination. Can you imagine how much we'd all pay at the grocery store if we did this?? never mind the $1.85/mile average freight costs, there just simply are not enough drivers to support this (Canada alone is short 50, 000 truck drivers)

You could ask your carrier to include in your contract a letter of guarantee that the driver is responsible for the safety of the product until final destination.  We ship LTL and my auditor just said OK.....there's nothing to be done here except use reputable companies...............point blank ask WHY it was unacceptable.

Guidance from the FDA

4. Finished Products

• ensuring that public storage warehousing and shipping operations (vehicles and vessels) practice appropriate security measures (for example, auditing, where practical, for compliance with food security measures that are contained in contracts or letters of guarantee)
• performing random inspection of storage facilities, vehicles, and vessels
• evaluating the utility of finished product testing for detecting tampering or other malicious, criminal, or terrorist actions
• requesting locked and/or sealed vehicles/containers/railcars and providing the seal number to the consignee
• requesting that the transporter have the capability to verify the location of the load at any time
• establishing scheduled pickups, and not accepting unexplained, unscheduled pickups
• keeping track of finished products
• investigating missing or extra stock or other irregularities outside a normal range of variation and alerting appropriate law enforcement and public health authorities about unresolved problems, when appropriate
• advising sales staff to be on the lookout for counterfeit products and to alert management if any problems are detected

Just to clarify - we sell mostly Private label water that goes by LTL.  One to 3 pallets per shipment.  Moving to our own trucks is not cost effective or practical.  Also we ship up and down the entire east coast, and west to about Illinois. 

We can't force full truckload purchases, or we might as well close the business, since it is the largest portion of our business. 

Historically - private branded water is not theft worthy by the pallet other than because you need water.   And if someone else buys water with Jim & Lisa's wedding picture on it, then I think that should be on the consumer. 

Can they re-brand it?  Yes but it will look like a label over a label, because you cannot effectively remove our labels without leaving large pieces of it behind.  We have actually tried multiple methods in house, mainly to fix our own mistakes which is why we know that doesn't work.  A re-branded water bottle in our case is obvious.   3 of them have Quality Food Policies , defense strategies etc and even publicize it on their website and our Big Carriers.  

Once the bottle itself has been messed with it is obvious, the water leaks, same with the cap.  

We use reputable carriers, all of the trucks from our local terminals have GPS monitoring.   With the new DOT laws I believe all trucks are required to have them now.  I just specifically know about our local guys, because we chose to only goes with the ones that had it, about 2 years ago. 

I can add it a supplier audit, but I really do not see the real value in it.  I am going to go see one of their terminals.  Confirm the security of the terminal and that is really it.  Driver ride along, no carrier is going to let that happen, that is an insurance nightmare. 

We also detain our drivers in the waiting room, take their keys and load.   

I will check on a letter of guarantee.  

I hear your pain, we ship LTL from Coast to Coast..............and naturally our product gets cross docked..............shelf stable hermetically sealed jars..............so same as you, the container is naturally tamper proof

Challenge the CAR...........which audit scheme?

SQF 8- Manufacturing, Module 11, and the Quality Code.  It was written under the Manufacturing Code.  I reviewed the FDA website on this, and we are pretty much doing everything they say.  Does that trump SQF?  I am leaning towards fighting it.  

Do you mind posting the actual non conformance comment?

As you are in the USA and I am not, the push for this clause is moderately different even though we are also SQF. it is not a federally regulated clause per say like it is as per FDA so that may be part of the issue