The days for spinning wheels are over. The time for full speed ahead with transportation food safety compliance is now.
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Explore this issueJune/July 2017
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As we go to press, businesses that are not defined by FDA as small or are not otherwise exempt must now be in gear with the Food Safety Modernization Act (FSMA) Final Rule on Sanitary Transportation of Human and Animal Food, effective April 5, 2017.
The FDA defines as “small” shippers and/or receivers employing fewer than 500 persons and motor carriers having less than $27.5 million in annual receipts. These entities are scheduled for FSMA compliance by April 5, 2018.
Simply stated, the final FSMA Sanitary Transportation rule, proposed in January 2014 and issued April 5, 2016, requires those who transport perishable food, be it by motor or rail, land or sea, to use sanitary practices to ensure the food’s safety.
According to FDA, the rule establishes requirements in four key areas.
- Vehicles and transportation equipment. This focuses on the design and maintenance of vehicles and transportation equipment to ensure that they do not cause the food they transport to become unsafe. For example, they must be suitable and adequately cleanable for their intended use and capable of maintaining temperatures necessary for the safe transport of food.
- Transportation operations. This includes the measures taken during transportation to ensure food safety, such as adequate temperature controls, preventing contamination of ready-to-eat food from touching raw food, protection of food from contamination by non-food items in the same load or previous load, and protection of food from cross-contact, such as the unintentional incorporation of a food allergen.
- Training. Training of carrier personnel in sanitary transportation practices and documentation of the training is required when the carrier and shipper agree that the carrier is responsible for sanitary conditions during transport.
- Records. Records include maintenance of written procedures, agreements, and training (required of carriers). The required retention time for these records depends upon the type of record and when the covered activity occurred, but does not exceed 12 months.
FDA notes that, with some exceptions, the final rule applies to shippers, receivers, loaders, and carriers who transport food in the U.S. by motor or rail vehicle, whether or not the food is offered for or enters interstate commerce. It also applies to persons, for example, shippers, in other countries who ship food to the U.S. directly by motor or rail vehicle (from Canada or Mexico), or by ship or air, and arrange for the transfer of the intact container onto a motor or rail vehicle for transportation within the U.S., if that food will be consumed or distributed in the U.S.
The rule does not apply to exporters who ship food through the U.S. (from Canada to Mexico, for example) by motor or rail vehicle if the food does not enter U.S. distribution.
FDA designates eight exemptions to the Sanitary Transportation rule. These include 1.) shippers, receivers, or carriers engaged in food transportation operations that have less than $500,000 in average annual revenue; 2.) transportation activities performed by a farm; 3.) transportation of food that is transshipped through the U.S. to another country; 4.) transportation of food that is imported for future export and that is neither consumed or distributed in the U.S.; 5.) transportation of compressed food gases (carbon dioxide, nitrogen, or oxygen authorized for use in food and beverage products, for example) and food contact substances; 6.) transportation of human food byproducts transported for use as animal food without further processing; 7.) transportation of food that is completely enclosed by a container, except a food that requires temperature control for safety; and 8.) transportation of live food animals, except molluscan shellfish.
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.”
Dr. Ryan likens any carrier of food to the human bloodstream. “If it’s not clean, it’s a problem,” he says.
Dr. Ryan is quick to emphasize that drivers don’t have to worry about cross-contamination if they are only carrying one thing, apples, for example. “But then if you carry an additional item you have to manage the situation,” he points out. “That can be difficult for some drivers.”
Compounding the confusion, Dr. Ryan mentions, is that the law says the shipper has to tell the carrier what to do, such as the shipper will specify temperature a product must be maintained at. “But industry says carriers and shippers have to respond to the buyer of food,” he says. “Thus, the carrier is caught in the middle, trying to meet demands of the law and of the industry.
Retailers and restaurants have been pushing carriers for some time in this regard. In short, all members of the supply chain have to assure that they meet the business needs of their customers and comply with new rules as well.”
All team members at John J. Jerue Truck Brokers, Satellite Beach, Fl., recently completed the aforementioned three-hour training course with Sanitary Cold Chain.
“The training was valuable to inform our staff and get them knowledgeable about FSMA and the changing food safety regulations,” says Michelle Renz, the branch’s office manager. “From new types of pallets to recordkeeping requirements, the new regulations will require everyone to consider details of their daily operations.”
Renz says the branch’s staff includes former drivers that now work in the office, as well as transportation brokers with more than 30 years of experience. “These seasoned team members are as eager as newbies to understand the details of the regulations that will thrust most small business trucking companies into the future of trucking,” she relates, noting that the branch works with a collection of drivers and trucking companies that they have rated as suitable with appropriate safety and insurance requirements to provide transportation services around the country.
“The FSMA training gave us details into the blueprint for the processes and data that will affect the future of the trucking business, for large companies as well as small fleet owners,” Renz points out. We are working with our stable of carriers so drivers understand the compliance regulations and can stay up with innovation in our industry.”
Since technology innovations are a major force disrupting the transportation industry, learning the details is what will set a good transportation planner apart from others, Renz emphasizes. “Each of our staff has completed training because the ability of carriers to adapt may determine their long-term business relationships,” she notes.
App User Manual
Sanitary Cold Chain has developed an app user manual for cellphones. “Drivers can enter data on washing, testing for food residue, loading, and unloading,” Dr. Ryan explains. “They can collect data on events at any time and place (such as during pickup, delivery, or washing), as well as monitor temperatures. They can also collect data for their personal FSMA rule compliance.”
This app user manual is available as a subscription service for both individual drivers and companies. “Each subscriber gets their own data base in a cloud,” Dr. Ryan relates. “The reports available from the cloud collected data allow drivers and managers to manage their operations to the new food safety standards.”
Ready to Roll
What might arguably be called the coolest innovation to hit the highway to date is a composite reefer trailer now offered by Wabash National Corp., Lafayette, Ind.
The company’s hottest new Cold Chain Series refrigerated van is constructed using a proprietary molded structural composite with thermal (MSCT) technology, which improves thermal performance by up to 25 percent and is as much as 20 percent lighter, while significantly improving puncture and damage resistance, according to Brent Yeagy, MS, MBA, Wabash National’s president and COO.
Molded structural composites have been used in aerospace, automotive, marine, and commercial construction for some time, and have previously been used by Wabash National in its refrigerated truck body. Yeagy says this is the first time the technology is being used in the trailer industry.
Wabash National’s new trailer is manufactured with all-composite sides and top. The trailer’s unique composite floor structure is 4.5 inches thick, while a conventional refrigerated van’s floor is typically 7.75 inches thick. The floor is also available as a composite structure/aluminum surface hybrid.
The more newsworthy detail, Yeagy emphasizes, is that this innovative floor boasts a whopping 50 percent increase in floor rating, which is how much fork lift load it can support.
“A standard reefer van floor is rated at 16,000 pounds and dry vans (those carrying dry goods, not refrigerated) are rated at 20,000 pounds,” Yeagy relates. “This new floor has a 24,000-pounds rating.
“The key take home message is that the composite floor offers a 50 percent increase in floor rating, with a much thinner structure,” Yeagy continues. “The benefits of these innovations to the transportation industry are improved thermal efficiency, reduced fuel costs, increased payload and cargo capacity, optimized utilization, and enhanced durability.”
Introduced as a prototype in February 2016, the all-composite refrigerated trailer is now in a limited production run of some 100 units slated to be completed by about September 2018.
Much of the production is being handled at Wabash National’s composites manufacturing facility in Little Falls, Minn.
“With its hybrid floor, our new refrigerated van can be used for both refrigerated and dry loads,” Yeagy points out. “That feature promises to improve profits for shippers as a result of increased backhaul opportunities, which is the ability to carry goods on a return trip.”
Robert Lane, MBA, Wabash National’s vice president of product engineering for Commercial Trailer Products, concurs that with the composite trailer being up to 2,000 pounds lighter than more commonplace refrigerated trailers, while owning the enviable 24,000-pound floor rating, refrigerated carriers can now double as a dry van when necessary.
“We achieved the weight savings by removing metal from the walls and floors,” Lane explains. “The box is a one-piece composite structure made of glass, resin, and foam. There is no metal anywhere in the box structure itself, however the rails are still made of metal and the customer can specify an aluminum floor surface.
“The company’s goal was to offer a fully-loaded refrigerated trailer, including the refrigeration unit, that weighs less than today’s dry van,” he continues. “As a result of the increased puncture resistance, carriers will be able to transport loads that are a bit more abusive than what is typically hauled in a standard refrigerated trailer.”
Thus far, four transportation companies have placed orders for the new composite trailers: K&B Transportation, Sioux City, Iowa; Werner Enterprises, Omaha, Neb.; Leonard’s Express, Farmington, N.Y.; and Combined Transport, Inc., Medford, Ore.
K&B Transportation accepted delivery of Wabash National’s first MSCT refrigerated van in April 2017. Brock Ackerman, owner of the company, believes that the reefer’s smooth interior wall promises to offer a real food safety advantage for food haulers like himself. “With the smooth wall, there will be limited areas where bacteria can get into and hide within the trailer,” he says. “That’s a big plus, especially in light of the FSMA transportation requirements.”
“With the continuing growth in cold chain infrastructure and the significant investment being made in home food delivery services, we’re very optimistic about the new trailer’s future, and we believe it has great potential to significantly benefit the food transportation industry,” Yeagy elaborates.
Telematics and Transport
If you’re up on the buzzwords flying around in the fast-paced world where food transportation meets communications, you already know that telematics is the branch of information technology that deals with the long-distance transmission of computerized information.
Definitely an interdisciplinary field, telematics encompasses telecommunications, vehicular technologies, road transportation, road safety, electrical engineering (including sensors, instrumentation, and wireless communications), and computer science.
Among its various capabilities, telematics can involve the integrated use of telecommunications and informatics, which is the science of processing data for storage and retrieval, for application in vehicles and with control of vehicles on the move.
Telematics is critical for recording pertinent data to meet shippers’ needs as well as for complying with the new FSMA sanitary transportation rules, says Gayatri Abbott, MBA, connected solutions product manager for Thermo King Corp. North America, Minneapolis, Minn.
“Recording, demonstrating, and retaining transportation temperature control data for 12 months is an important proof of compliance element required within FSMA,” Abbott points out. “With a Thermo King telematics solution, carriers can easily deliver proof-of-compliance data to their customers for any given point throughout their travels.”
To that end, Thermo King’s trademarked telematics offerings include the company’s signature TracKing, an integrated solution that gives fleets real-time visibility of their refrigerated assets, allowing them to monitor critical cargo temperatures, trailer locations, and refrigeration units through the dispatch process from pickup to delivery. TracKing was first introduced in Europe in 2006, and then in the U.S. in 2009.
“TracKing is a web-enabled system that provides fleet owners the tools to protect their assets, improve their response times, and manage their operating costs while maintaining the highest food safety and quality standards,” Abbott relates. “With TracKing, shippers can monitor and control temperatures, track and trace shipments, and receive real-time notifications for time-sensitive events such as temperature changes, open doors, refrigeration system fuel levels, and battery life.”
Available since January 2016, TempuTrak is Thermo King’s temperature and location management tool for direct-drive trucks, heaters, and non-Thermo King refrigeration units that provides visibility of assets on the TracKing platform.
TrailerTrak, also on the market since January 2016, is a GPS-based trailer management solution for non-refrigerated trailers, tankers, and flatbed trailers that provides fleets with real-time and historical trailer status information, also on the TracKing platform.
“Depending on the fleet’s needs, Thermo King’s entire telematics portfolio offers a full spectrum of services ranging from full visibility of temperature-sensitive cargo to basic tracking and tracing, or simple location monitoring 24/7 from a desktop, tablet, or smartphone,” Abbott says, noting that the TracKing mobile app is compatible with both Google Android and Apple iOS devices.
“As technology has evolved, so have our offerings and capabilities and we continue to keep our customers’ needs at the center of it all,” Abbott points out. “We understand the importance of maintaining perishable goods at the right temperature and the need for fleets to manage their refrigerated assets throughout their operations. We also offer the unique ability to download the refrigeration unit controller for diagnostics, as well as setting special customer specific cargo profiles on the refrigeration unit, all remotely via TracKing without having to touch the refrigeration unit.
“Real-time remote monitoring not only offers peace of mind, but also gives carriers the ability to react and correct potential issues before load integrity is compromised or a delivery schedule is interrupted,” Abbott adds. “All of these technologies provide traceability and temperature management, enhanced cargo protection and food safety, greater fuel savings, improved fleet efficiency, tighter security, and better data management and utilization.”
Leake, doing business as Food Safety Ink, is a food safety consultant, auditor, and award-winning journalist based in Wilmington, N.C. Reach her at LLLeake@aol.com.