The Sanitary Cold Chain
TransCert Transportation Certification

TransCert FDA FSMA Food Safety & Quality Compliance for Food Transportation Operations



Food During Transportation Operations

FSMA

FDA Proposed Rule on Sanitary Transportation of Human and Animal Food


Published January 31, 2014 by the FDA.  Details at: 

http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm383763.htm


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Goal of the Rules

To prevent practices that create food safety risks such as failure to properly refrigerate food, inadequate cleaning of vehicles between loads, and failure to properly protect food during transportation.


Scope of the Rules

                                                        A. Scope (§ 1.900)

                                                        B. Applicability (§ 1.902)

                                                        C. Definitions (§ 1.904)

                                                        D. Vehicles and Transportation Equipment (§ 1.906)

                                                        E. Transportation Operations (§ 1.908)

                                                        F. Training (§ 1.910)

                                                        G. Records (§ 1.912)

                                                        H. Waivers (§§ 1.914 – 1.934)


                                                          Requirements Established for

                                                                     Shippers
                                                                     Carriers
                                                                     Receivers
                                                                     Vehicles and Transportation Equipment
                                                                     Transportation Operations
                                                                     Intrastate, Interstate and International
                                                                     Food Consumed in the United States

Text from the Food Safety Modernization Act




Records required by FDA auditors in the case of suspected

adulteration - including transportation



 

TITLE I--IMPROVING CAPACITY TO PREVENT FOOD SAFETY PROBLEMS

SEC. 101. INSPECTIONS OF RECORDS.

"(1) Adulterated food.-- Use of or exposure to food of concern. If the Secretary believes that there is a reasonable probability that the use of or exposure to an article of food, and any other article of food that the Secretary reasonably believes is likely to be affected in a similar manner, will cause serious adverse health consequences or death to humans or animals, each person (excluding farms and restaurants) who manufactures, processes, packs, distributes, receives, holds, or imports such article shall, at the request of an officer or employee duly designated by the Secretary, permit such officer or employee, upon presentation of appropriate credentials and a written notice to such person, at reasonable times and within reasonable limits and in a reasonable manner, to have access to and copy all records relating to such article and to any other article of food that the Secretary reasonably believes is likely to be affected in a similar manner, that are needed to assist the Secretary in determining whether there is a reasonable probability that the use of or exposure to the food will cause serious adverse health consequences or death to humans or animals.
"(3) Application.--The requirement under paragraphs (1) and (2) applies to all records relating to the manufacture, processing, packing, distribution, receipt, holding, or importation of such article maintained by or on behalf of such person [[Page 124 STAT. 3887]] in any format (including paper and electronic formats) and at any location.".

FDA Guidance for Industry:

Sanitary Transportation of Food

III. Discussion


In our effort to assist the food transport industry in preventing food safety problems during transport while we are implementing the 2005 SFTA, we want them to be aware of the following problem areas where food may be at risk for physical, chemical, or biological contamination during food transport:


  • Improper refrigeration or temperature control of food products (temperature abuse).
  • Improper management of transportation units (or storage facilities used during transport) to preclude cross-contamination, including improper sanitation, backhauling hazardous materials, not maintaining tanker wash records, improper disposal of wastewater, and aluminum phosphide fumigation methods in railcar transit;
  • Improper packing of transportation units (or storage facilities used during transport), including incorrect use of packing materials and poor pallet quality;
  • Improper loading practices, conditions, or equipment, including improper sanitation of loading equipment, not using dedicated units where appropriate, inappropriate loading patterns, and transporting mixed loads that increase the risk for cross-contamination;
  • Improper unloading practices, conditions, or equipment, including improper sanitation of equipment and leaving raw materials on loading docks after hours;
  • Poor pest control in transportation units (or storage facilities used during transport);
  • Lack of driver/employee training and/or supervisor/manager/owner knowledge of food safety and/or security;
  • Poor transportation unit design and construction;
  • Inadequate preventive maintenance for transportation units (or storage facilities used during transport), resulting in roof leaks, gaps in doors, and dripping condensation or ice accumulations;
  • Poor employee hygiene;
  • Inadequate policies for the safe and/or secure transport (or storage during transport) of foods, e.g., lack of or improper use of security seals;
  • Improper handling and tracking of rejected loads and salvaged, reworked, and returned products or products destined for disposal; and
  • Improper holding practices for food products awaiting shipment or inspection, including unattended product, delayed holding of product, shipping of product while in quarantine, and poor rotation and throughput.


To address some of the problems enumerated above, we recommend that persons engaged in food transport concentrate their efforts at this time on the following, broadly applicable preventive controls:


  • Appropriate temperature control during transport;
  • Sanitation, including:
    • Monitoring and ensuring the sanitation and condition of transportation vehicles as appropriate;
    • Pest control; and
    • Sanitation associated with loading/unloading procedures;
  • Appropriate packaging/packing of food products and transportation units (e.g., good quality pallets, correct use of packing materials);
  • Good communications between shipper, transporter and receiver; and
  • Employee awareness and training.
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