The FDA defines a carrier as a “person who owns, leases, or is otherwise ultimately responsible for the use of a motor vehicle or rail vehicle to transport food. The carrier is responsible for all functions assigned to a carrier (as per the heart of the FSMA rule) even if they are performed by other persons, such as a driver that is employed or contracted by a trucking firm. A carrier may also be a receiver or a shipper if the person also performs the functions of those respective persons” as defined in the rule.
Perhaps second only to maneuvering a sharp mountain curve in an ice storm, meeting the FSMA training requirement is currently the scariest and most troublesome concern that transportation professionals are dealing with, according to John Ryan, PhD, a co-founder and principal of Sanitary Cold Chain, Palm Bay, Fl. Sanitary Cold Chain provides food safety training, audit, and, through its trademarked TransCert arm, certification support to carriers, shippers, and receivers in the supply chain.
Whole New Segment
While all other food industry stakeholders have been training their personnel for years, food safety training for the transportation industry has just recently become a whole new important segment of the food chain, Dr. Ryan says.
“Until the dawn of FSMA, the trucking industry has not been involved in food safety,” he points out. “They concerned themselves with worker safety, focusing on how many hours one can drive safely. Now, to comply with FSMA, they have to develop food safety training. But FSMA has not been in the faces of the food transportation industry with high pressure. Thus, in the days leading up to the April 5 compliance deadline, the big companies were finally feeling the pressure and were panicking. Not surprisingly, we were hammered with requests for assistance, especially in the six weeks prior to the deadline. Many players in the food transportation industry have been telling us, ‘We don’t know what to do.’ So, we have been doing a lot of handholding.”
Dr. Ryan says his firm has conducted about 100 training webinars for the transportation industry in the last two years. “Now the demand for two-day seminars for 12 to 15 people has been picking up,” he notes.
Sanitary Cold Chain offers the training required by FSMA for all personnel engaged in transportation operations upon hiring and as needed thereafter. Along with webinars and in-person seminars, a third option is download packages companies can use with their employees.
Training certificates are available from Sanitary Cold Chain for completion of its three-hour course that highlights the three required topics, including responsibilities of the carrier under the final rules (1 hour), awareness of potential food safety problems that may occur during food transportation (1 hour), and basic sanitary transportation practices to address those potential problems (1 hour).
“This training is available with and without competency exams,” Dr. Ryan notes, adding that successful completion of such exams is not required to be FSMA compliant.
“We help our clients start planning their transportation food safety programs by showing them how to develop a process and a flow chart,” he relates. “We help them to piece all the components of transportation food safety together and document them. The various steps in the flow charted process include shippers’ product pick up spots, temperature monitoring and control, washing the truck, and the temperature of the wash water, among others. Questions addressed include what materials is the trailer made of and will we use sanitizer?
“One important thing is that we dispel the myths that you do not have to wash trailers after each load,” Dr. Ryan continues. “And we emphasize that you don’t just wash the truck out, rather you have to consider are you getting it clean. We explain follow-up tests, such as ATP (adenosine tri-phosphate) swabs, to determine food residue. The bottom line we stress is that you need to not just move food, but move it without contaminating it. You have to know the food safety rules for the specific products you are carrying, be they frozen food, fish, produce, or whatever, and you must consider the potential hazards for them.”