Is it OK to let our UPS driver load our product unsupervised?

Good morning,

Preparing for my companies first audit and am concerned about an aspect of our process.

At the end of the day, we usually have about 20 skids or so of product to be shipped UPS. We locked the doors at 5 and at some point (Usually within 15 minutes or so of closing) a UPS driver shows up with a trailer and loads the pallets himself onto the truck. He has our garage password and can access the shipping/receiving area and no where else. The driver goes directly from our warehouse to the UPS warehouse where pallets are dissembled and packages are prepped to ship.

Does this process need to be changed? Obviously you have no idea what can happen to your product when dealing with LTL loads, so would this be considered a similar situation?

Thanks,

Good morning,

 

Preparing for my companies first audit and am concerned about an aspect of our process.

 

At the end of the day, we usually have about 20 skids or so of product to be shipped UPS. We locked the doors at 5 and at some point (Usually within 15 minutes or so of closing) a UPS driver shows up with a trailer and loads the pallets himself onto the truck. He has our garage password and can access the shipping/receiving area and no where else. The driver goes directly from our warehouse to the UPS warehouse where pallets are dissembled and packages are prepped to ship.

 

Does this process need to be changed? Obviously you have no idea what can happen to your product when dealing with LTL loads, so would this be considered a similar situation?

 

Thanks,

Interestingly enough we have the same situation at my clients facility.  Everything is documented, that is #1, the driver has an access card to pop open the sliding gate and enters the rear area of the building about 6pm, an hour after closing. He then proceeds to a set-aside locked (small) structure and using the available power jack loads up about 10-15 skids. The access card he has is assigned to him (by name - not to the company) that he uses at the gate, thus each entry is recorded. He then used the same access card to open the door to the small structure. The card can only be used for those two things and he can not get into the main facility. So everything is recorded. After he leaves the door auto-locks and on approach to the gate he had to use the card again to get out.  The whole process is controlled and includes cameras at the gate, exit, structure door and one facing the back of the truck so that we see him relock the trailer, etc.  There are written procedures, the driver is designated with an alternate and both are required to read, understand and sign off on the company GMPs for service providers. There is also a written security protocol in place.   And, also the UPS logstics facility gets inspected by the company as well.

 And, also the UPS logstics facility gets inspected by the company as well.

That's a first for me. Is it a small town?

Glenn's recommendations are spot on. Not everyone has their own fleet of trucks and a ton of food is shipped LTL under normal small company freight operations. The best thing you can do is document and establish that if there was ever a problem, you would be able to track down the what, when, and who interacted with the product.

-Austin

Hello!

While your UPS driver may be trustworthy, the system could be in direct violation of the FDA Food Safety Modernization Act (FSMA) if you don't have very specific processes in place to keep track of lot numbers/product codes going out the door, and driver/substitute driver names, driver fingerprints or other identifier. Check your systems and see if they'd hold up in an FDA audit. 

Hello!

While your UPS driver may be trustworthy, the system could be in direct violation of the FDA Food Safety Modernization Act (FSMA) if you don't have very specific processes in place to keep track of lot numbers/product codes going out the door, and driver/substitute driver names, driver fingerprints or other identifier. Check your systems and see if they'd hold up in an FDA audit. 

Hi Michelle,

A vulnerability assessment of the activities would need to be conducted. But given my meal delivery service does not have to fingerprint every UPS driver that drops it off, your interpretation appears a bit overzealous. Also, packaged shelf stable sealed foods are completely exempt from all of the FSMA sanitary transport requirements (assuming that applies if we're in UPS territory)

FDA isn't ready to tackle food transport as an industry, so just places the burden of safety on manufacturers and receivers. Heck, all farm activities are exempt because it's just too complicated.

Hi Michelle,

 

A vulnerability assessment of the activities would need to be conducted. But given my meal delivery service does not have to fingerprint every UPS driver that drops it off, your interpretation appears a bit overzealous. Also, packaged shelf stable sealed foods are completely exempt from all of the FSMA sanitary transport requirements (assuming that applies if we're in UPS territory)

 

FDA isn't ready to tackle food transport as an industry, so just places the burden of safety on manufacturers and receivers. Heck, all farm activities are exempt because it's just too complicated.

Hello, FFF--

I was replying to Austin's original post, and he does not specify what he's shipping. I don't think i'm being overzealous--there's no room for magical thinking when it comes to the FDA. Austin's company may have a nice trusting relationship with their UPS driver, as do we, but under no circumstance would I allow any drivers unsupervised access to our plant. It sounds like they should have additional controls in place to prevent intentional contamination of their outgoing products. Cameras? Tamper-evident tape/wrap? Because it takes just one person to cause a major problem from which their business may not be able to recover.

If your Risk Assessment says the level of risk is low enough and you can document access and preventive measures to ensure the safety of the rest of the facility, I don't see an issue with it.

Putting on my Safety Manager's cap here but, I would not allow anyone except a certified equipment operator and company employee to use company equipment on company property. Contracts and agreements be hanged, you're on the hook for any injury that might occur. What if the UPS person injures themselves badly of is pinned and unable to get free and, God forbid, dies - on your property - using your equipment. At that point he is viewed technically as your employee and the liability is all yours. Doesn't sound worth the potential cost. I find it hard to believe with you shipping that much every day that UPS wouldn't be able to offer better hours for pick ups unless you haven't requested it and are willing to continue the way it is. You might want to ask your Risk Management (Insurance) company for some guidance. If they don't know about it already, you might be shocked at their response.

Yea I'm with Hoosiersmoker on this one, even if you are not worried about Food Defense or product safety, I'll be damned if my company's owner ever let a non employee touch things in here with no supervision!  Insurance would absolutely have an issue with that.  

We have employees stay until UPS gets here.  They love it when UPS is late, get some relaxed overtime in.  And all that overtime will be cheaper than an on-site injury to the UPS driver.