After several years of development following its passage in 2011, the Food Safety Modernization Act (FSMA) is now in effect. As the legislation transitions the U.S. Food and Drug Administration (FDA) into a law enforcement authority, versus regulatory agency, it’s critical for shippers and couriers within the food industry to understand its impact on temperature-controlled transportation.
Carry Responsibility for Food Safety
One of the most significant changes ushered in by FSMA is how it delegates the responsibility of food safety. Instead of placing accountability with the individual or organization in possession of a shipment, such as a courier or a distributor, the burden is almost always with the producer or shipper.
Exceptions to this food safety transportation standard are contractual agreements. You may, for example, sign a contract with your courier that states they are responsible and liable for the safety of your food items during transportation. It’s essential to note that accountability can shift back to you. If your contract, for instance, assigns compliance responsibilities to a party not covered by FSMA — thus, anyone other than shippers, receivers, loaders and carriers — your company is liable for their non-compliance.
Develop a Temperature Monitoring Mechanism
In 2011, FSMA required companies to use temperature indicating or temperature recording devices during transportation. That changed, however, and the FDA now mandates that shippers and carriers implement a temperature monitoring mechanism. This requirement is perhaps one of the most critical factors in food safety transportation, as it ensures parties keep products at an optimal temperature for freshness, flavor and texture — which avoids the potential financial losses and brand damage of spoiled food entering the marketplace.
As a part of your temperature monitoring mechanism, your carrier must maintain a record of temperatures. The reason for this requirement is that FSMA mandates that couriers produce documents upon request from either you or the FDA. The most trusted method for fulfilling this food safety transportation standard is via data loggers.
Create Sanitary Procedures
Per FSMA, food transportation must follow the shipper’s established sanitary procedures. For every product your company produces, you will need to develop a set of sanitary protocols, which can detail how to load, store and transport your goods, as well as clean the transporting vehicle.
Provide your instructions in a physical format to your courier — and loaders if the procedures apply to them. If your sanitary requirements change over time, ensure your team revises the existing standards and provides them to your courier and loaders before the next shipment.
If your carrier deviates from your sanitary protocols, it’s vital your company acts, as you’re liable for their non-compliance with food safety transportation standards. Potential actions you can take include modifying your instructions to be more concise, as well as terminating your contract.
Implement a Food Safety Training Program
With FSMA’s passage, it’s critical to review your existing carriers. FSMA requires carrier personnel to undergo food safety training, which ensures drivers, loaders and other staff possess the necessary knowledge and experience to handle temperature-sensitive goods.
The FDA asks that drivers, in particular, undergo a one-hour course before starting. While the FDA is in the process of collaborating with trusted organizations to develop a set of certified classes, there are none available now to accommodate the FSMA’s food transportation standards.
It’s recommended, however, that your couriers direct their drivers and staff to similar courses. This act demonstrates to the FDA that your company and its partners are committed to educating their staff about food safety practices.
Establish Recordkeeping Protocols
As Title 21, Part 11 of the Code of Federal Regulations (CFR) emphasizes, recordkeeping is significant to the FDA. As a result, FSMA mandates extensive recordkeeping by shippers and carriers. The specific focus of documentation in food safety transportation is temperature.
Carriers must provide temperature documentation on request, as well as maintain records regarding vehicle maintenance and performance, fleet movements and routes. Documents like these can often serve as evidence that your drivers understand and comply with FSMA’s food transportation requirements.
Define Preventative and Reactive Controls
Via FSMA, the FDA asks companies to be proactive and reactive. That’s why your business, as a producer and shipper, must establish a food safety plan and risk-based preventative controls, as well as evaluate hazards in your facility and supply chain.
As a part of your hazard analysis, you should identify how your company will manage these risks and counter them if they become an active hazard. You may also implement some corrective actions to alleviate specific hazards. Separate from your hazard analysis, your team should also develop a plan for recalling products.
It’s essential to note that per these new food safety transportation standards, the FDA can now recall food items without your company’s permission. They may only use this power after notifying a producer about the risk of their product and after the producer does not take action.
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