Understanding the FDA Sanitary Transportation Regulations



hello ladies and gentlemen welcome to read ish in 41 of food safety Friday's today we've got a new guest presenter delighted to say Kathy Crawford vice president of the hassock consulting group and cathy is going to be presenting on the topic understanding the FDA sanitary transportation regulations I'm not going to tell you anything about it because I don't know anything I learn every week as along with you I just like to say before that thanks to the sponsors food trace analytics FSS see 22,000 safe food 360 on mettler-toledo these companies help to bring these webinars to you free of charge each week and you get certificate and their logos on the certificate so pay heed to that because they help to bring the webinars free to you as do the presenters and we've got Kathy here aya Kathy live from Washington DC how are you doing wow good is it sunny there today it looks it looks bright not too bad and for now no snow on the ground that's what we want if you can get your presentation ready I'll tell the audience about next week's web browser okay Kathy come back to your night ladies and gents next week we have another new presenter I've loaded it in the sidebar so you can click on that and register directly from the sidebar lock in a new window it won't kick you out of the webinar the subject next week is foreign supplier verification program for food importers and the presenter another new presenter Cornelius Hugo who's the global innovation manager at aib international so another one related to the Food Safety Modernization Act ok so if that applies to you please join us next week even if it doesn't join us and just say hello and have a chat and meet up with the regulars okay we've got polls and things today and interactions that we'd like you to take part in so I'll be back for them later but for now over to Kathy okay Kathy all yours lemon you can hear okay yes perfect okay great so thanks for that introduction and I again want to welcome everybody I'm really be able to participate in this completely Friday when I looked at one of the past topics that have been discussed and looked at the future schedule like alarm great topics and a lot of them do pertain to the food safety modernization act but what surprised me is how little attention there's been to sanitary transportation the sanitary transportation regulation is coming up very quickly to do at the end of March so a little over a month from now so I think it's going to become really important that we review those requirements today that will take a nice to look at what led to the rule and the background and how we got where we are today in the late 1980s there were newspaper reports of what became meme unaffectionate Lee known as New York produce and I'm not trying to insult New York or actual Newport Rhode ooze what I was there were ports that produce was being shipped from the producing areas of the country in the United States for example Florida California the growing areas into the highly populated cities for example New York and those cities would of course consume the produce but they also generate a lot of trash the same vehicles that were delivering produce were picking up trash and then taking that to areas generally in the Midwest where they had these hauling or dump sites and so in the late 80s we were seeing these headlines that say things like garbage cargoes are endangering food and that was in the I think the Chicago Tribune at the time and so there was this public outcry people were concerned that food simply wasn't safe and so this led to the regulation in nineteen ninety nineteen ninety sorry called the sanitary food transportation act it's very typical that public outcry leads to regulations and that's exactly what happened so this act addressed contamination of food from non-food like trash or chemicals and things like that and it was supposed to be implemented by the d-o-t or the Department of Transportation well it appeared that the d-o-t didn't have a lot of time for this and really they had their hands full already with just plain safe driving so not much happened so not long after that in 1994 there was a huge incident and this was where a bulk tanker had been used to deliver raw egg and then later killed to use a cream mix so obviously this is a bad combination there were mixed reports of the results of this incident I read in one place that there were 3,000 people who were ill and in another place it said there were 200,000 people who became ill so there's a little bit of a disagreement on the actual statistics but it got a lot of public attention and that's important because public attention in public outcry is what leads to regulations so this time change took a little while but in 2005 Congress moved the jurisdiction of transporting safe food out from under the Department of Transportation over to the FDA and then the other thing they did was add to the rules that it includes food to food contamination because previously it was only a concern about non-food contaminating food so it made it a little bit more broad and it put it under the FDA not too long after that came what was called the 2007 interstate food transport project and this was just a project where vehicles were actually stopped in the road and they checked conditions it wasn't regulatory in nature it was just an investigation and a learning project and what was learned from that project was we still have a lot of concerns there were a lot of risks a lot of insanitary conditions observed and this led to the 2010 guidance that the FDA put out for sanitary transportation so if you just kind of look briefly at the supply chain and everyone has a slightly different version of what it looks like whether you're dealing with animal products or plant products there's various steps in the chain and each major step has regulations and rules in place that apply to food safety and typically this is going to be a hasit plan or a food safety plan but the problem is the lines in between each stage didn't have strong rules we didn't have assurance that safety was going to be maintained in transit and I think one of the reasons it's taken so long to arrive at regulations is because we're talking about the difference in the united states between intrastate transit and interstate transit where in one case things are going to be managed by state law and in another case it's going to be federal law for Food Safety Modernization home and in this particular rule on sanitary transportation the federal law is going to apply to both so transportation within the state as well as between states so it's truly going to strengthen the supply chain that we typically look at including the lines in between each step so we had this guidance put in place but we were still seeing issues and this is before implementation of FISMA we're seeing things like the two pictures of the truck floor here where you see blood stains on the floor one was a vehicle that had been presented to be loaded with bakery items that's not okay the other one was presented at a place where they were going to load ready to eat meat products again blood stains on the floor that's unacceptable there's a lot of photos and examples where produce transport shows evidence a lot of dirt may be decomposed food in the vehicle and then there's evidence that you can just see on the highway where the vehicle itself really isn't ideal for protecting the safety or the quality of the food so we're still seeing issues and we're starting to wonder you know do we really need this law and that's where FISMA came from in terms of changing this 2010 guidance into a regulation and so we have a little bit of a pole I'm curious to find out if you are aware of a significant outbreak other than the one I mentioned in 1994 that was known to have been linked to sanitary transport sorry Kathy nepal right okay um this question there are you where are you aware of a significant outbreak other than the one mentioned from 1994 known to have been linked to in sanitary transport if you know that can you type it in the sidebar let's see if there's any clever people are are people with a memory if you do yet type no i'm not aware if you don't know no no i don't know i've got to hold my hands up I don't know why we are seeing a lot of Mars chemicals in the wine tanker Marilla is that no no okay so consensus is not unless the unless it was that to do Skippy peanut butter uh not necessarily transportation but that's a good guess right laughter we'll have to bow to your superior knowledge cafe I don't know that that's the case but the pole is fascinating because when you read about why this law came into place they claim or they state that it's because of illnesses and outbreaks and yet none of us have heard of any just fascinating how this happens the laws get created because of public outcry not necessarily because of facts but we the walk around on this particular law they state it led to it and the number one thing is that one incident from 1984 the people on the slide 19 only course but the other that they site was a report about feed a report from Michigan State that was a truck assessment project there was a news report of a grand total of two hundred pounds of food that was contaminated in Indiana there was a newspaper report of a small amount of food that was contaminated in Michigan and a Michigan police report about vehicle enforcement records so of eight different citations that led to the law three of them actually came from Michigan and I have no problem with that because I'm a Michigan State Fred well in a way I applaud what's going on because it's proactive instead of reactive but I think it's important to point out with pride that despite the shortcomings we might have in transportation and sanitary transportation issues this is proactive and we're actually doing fairly well and the goal is to ensure that we maintain safety over time so it arose from this 2007 report that had basically 13 key risk areas and this is a summary of what some of them were and they're really the backbone of the new regulation the number one concern is improper refrigeration for foods that require refrigeration and then of course failure to prevent cross contamination or we'd call it cross contact if it was allergens improper packing or holding meaning not segregating things as we should there were design construction and maintenance issues where vehicles were just not in the right condition to protect the food as control concerns employee training and hygiene concerns now think about your average truck driver makes you go hmmm with there's room for improvement here and then they also cited a lack of policies and improper tracking of rejected Freight knowing where it went when it was rejected so those are all the concerns ah and again it's based on that guidance with a goal of ensuring practices don't increase risk there's always going to be some risk we can never eliminate it at all but through transportation it never should be mentioned earlier it covers interstate as well as intrastate Commerce and the final rule is do March 31st so whatever we talk about today chances are it won't change a lot but we do have to read the final rule when it comes out and pay attention to that detail what kind of surprises me is what's not included in the rule air and water transport is not included we're only talking about ground transport small businesses are not included shelf-stable or fully enclosed products like canned goods are not included live animals not included food gases meaning things that you might use to add guests to a soda machine that sort of thing are not included we call them racks here it stands for raw agricultural commodities those if they are from a farm are not included that particular part of the rule can get very complicated and if you're in the industry i recommend you closely read the definitions a raw agricultural commodity is going to be like a vegetable or a fruit its produce that might be washed or it might be treated but it's going to be unpinned and in its natural form so take some corn that came from the field that's a raw agricultural commodity but if you peel it and shuck it it no longer is a raw agricultural commodity and now it will fall under the law and then there's extensive wording within the law as to the death a farm in certain circumstances farms can in a very limited way do some processing and I hesitate to you it's that word because it's very carefully defined but those involved in what might be a farm need to read the definition of farms so that it's very clear whether or not you're under the rules of the transfer sanitary Transportation Act so other things that are also exempt would be food that is being imported with the intent to export without any further processing so that's something that's shipped direct through for example from Mexico to Canada through the United States without changing the food product itself and the other foods that are not included are those that are regulated in other ways for example meat and poultry are regulated in the United States by the USDA Food Safety Inspection Service and this is an FDA law so it is it only applies to FDA regulated foods so it's all these exceptions after a while although I applaud the proactive nature of the rule I start wondering what does it apply to because it also has exceptions for things like catering Airlines and schools so what is included in is exposed food so food that's not completely packaged that's transported by rail or by Road that's not from a farm and that's regulated by the FDA so this would be things like maybe prepared salads or sandwiches or frozen foods or seafood so those are some of the items that do fall under the law so we get to okay what is actually in this law it has six basic sections like any good regulation there's a long bit on definitions and we'll go through some of those today it covers vehicles and transportation equipment and then it goes to the operations and the use of that equipment there's a specific section on training a specific section on records and then section 6 which we're not going to really spend time on today is about waivers which is a part of the law that allows companies to become exempt from it based on risk assessments and requests for exemptions that would have to be worked out with the authorities on the right hand side of the slide you see my summary of the law this is not a legal definition but if you want to summarize what it says in my opinion you must prevent what I would call the I've forbidden things unacceptable condition so it's food that is filthy putrid decomposed unfit or injurious in any way those five things are repeated many many times in the regulation so I think it's beneficial to remember them I just call them the five forbidden conditions so here's some of the key definitions we need to look at who is a shipper a super is a person who initiates the shipment of a food by motor vehicle or rail vehicle notice it's not the person who actually does it that's the carrier but a key part in the definition of shipper is it could be someone who never even saw or touched the food product it could be a broker or a distributor who doesn't even see the food but they initiated the shipment so keep that in mind there may people some people who think oh I'm not involved in transportation I'm just a broker and I make phone calls but if you arrange for the shipment you are the shipper the carrier is much more straightforward as the person who owns leases or is responsible for that motor vehicle or the real vehicle it's going to be the driver or the drivers boss or the drivers company and the receiver that's also very straightforward is the person who received the food after transportation whether or not it was the final step in the chain so it applies to anyone who is receiving the food that's covered under the law so what exactly are we talking about in terms of a few more definitions what is transportation very broad definition it's any movement in commerce by motor vehicle or rail vehicle and it's going to cover only certain foods as we mentioned before but keep in mind this isn't necessarily what you imagined as the giant trucks on the highway it's also the smaller trucks and it could include a personally owned vehicle how many people work for a company this isn't a whole question because I didn't set it up but how many times have you seen an owner or a salesperson or someone who's in your research and development department say oh I'll just take this over there in my car those type of situations could be under the new law so we have to be really careful about that I think the industry in general isn't used to being as regulated as what's going to be coming in the next few years and then the next definition here on this slide is also very important food not fully packaged you may think a food is fully packaged because it's in a bag or a box but if that bag or that box is vented in any way now it's going to be considered not fully packaged under the new regulation a couple more definitions definitions are really important when it comes to regulations aren't they so what is a vehicle we talked about what's transportation now they have to define what is a vehicle and you would think we all know that but it's very specific it's motorized and it's on land so we're not talking about you know by air or by sea but it also includes items used in translation other than vehicles that's key because now we're talking about equipment things like maybe pallets or totes or bins even things like hoses pumps fittings or gaskets when you have bulk transport of things those are included under vehicles and equipment and under the law so the driver the carrier is responsible and we'll talk about this later but they're responsible to provide equipment that's appropriate for use and that's not just the truck that's the pallet jack that it's in good condition that's the pallets that's all kinds of things that might be associated with transportation operations one more definition here that's important if you haven't seen it before it's called atcs food really common phrase used in food safety training here in the US and I know it's not all us folks on the line so TCS stands for temperature control for safety time and temperature of course and so that applies to temperatures that must be refrigerated or frozen TCS foods might be things like shell eggs or sprouts but not necessarily things like bread or potatoes or sugar or flour that are going to be shelf stable so we've gotten a majority of the definitions out of the way now let's take a look at vehicles and equipment that was the second major section in the law and I do highly recommend the written maintenance program although the law doesn't require it but it's going to be the requirement of those involved in transportation operations that you're doing the right thing and you know how to do it so written right written procedures enhance your ability to prove that you follow the law first get to make sure equipment is cleanable which means we want to use more metal we want to use things that are in good condition and less wood and then it talks about good workmanship which means watch out for bad welds minimize would absolutely don't use glass unless it's necessary and then make sure all these surfaces within the vehicle are corrosion resistant or they're not laminating or pitting or blistering according to their intended use you also might want to take into consideration security as to whether or not the vehicle can be made secure for food defense or food fraud reasons so as we mentioned earlier when we think vehicles and equipment it's not just the truck it's the pumps the hoses the gaskets the pallets look at that picture of a pallet that was amazing that that was actual photo from a company I work with a pellet that arrived that was supposed to be used if it hadn't been rejected and it was damp and it was dirty and it was moldy and for them it was absolutely rejected and was unacceptable and in the future not only will it be unacceptable it'll be illegal and that's important because the regulatory environment is going to change things for us another thing just while we're on the topic of pallets to keep in mind is watch for what might be stamped on the side of a pallet if the pallet looks great that it's in good condition and it's going to be used for food but on the side it has a stamp that maybe says Acme pest control company you might not want to use that pallet you should know a history of the pallet and whether or not it really is appropriate for food use so the vehicle and equipment both matter you have to make sure that you're able to maintain sanitary conditions and avoid what I keep calling the forbidden five so if you have to make temperature you have to make sure your mechanized systems your reefer units and such are in good shape there are options to allow insulated containers and that's that's perfectly fine as long as you can demonstrate they work you need thermometers that are fitted to the equipment and you need to make sure that you have the capacity to cool even the largest load on the hottest day and the longest trip the other things you want to take into consideration for the vehicle and the equipment would be how you prevent or manage spills and I've seen situations where as Phil is cleaned up and there's a material they use sometimes to absorb spills and it's called speedy dry is one particular name brand and it took care of the spill but the driver forgot to sweep up and get rid of that spill managing agent and so when he showed up at the next location there's some white powder on the floor and the vehicle was rejected so keep in mind when you take care of spills you have to take care of them completely other things with vehicle and equipment design of course we need to prevent harborage is for pests and typically we think of larger pests and that they're not going to have a place to hide in a truck but don't forget this includes small things like ants and other insects that also have to be controlled and when you look at pest control make sure the activities are both safe and legal most of our carriers or our truck drivers are not trained pests chemical applicators and as sanitary transportation moves into a legal environment we have to make sure that we're following the regulations whether it's the FDA with sanitary transportation or the EPA of the United States that governs pesticides so color pest control and sanitation when looking at your equipment so we've got the people in place with a few definitions we've got the equipment in place now we're finally going to start doing some thing about actual sanitary transportation certain rules apply to everybody namely preventing those forbidden five or less by the unacceptable conditions and if you forgot what they are I'll remind you we have to avoid filth putrid food decontamination of food or food that is anyway fit or injurious and those are the five conditions more specifically we have to prevent your classic contamination routes and raw to ready to eat or from non-food to food or we have to prevent cross contact between allergens keeping in mind that in the United States right now there's only eight allergens that must be declared but of course in other countries there are more and we have of course that key requirement to prevent the growth of microorganisms that might lead to pathogens or toxin formation um under general transportation operations I want to mention quickly to that the law actually states that fireman's are meant for the carrier certain requirements are meant for the receiver and certain requirements are meant for the shipper if the law does not state who has to comply then it does say everyone must comply so if there's a statement in the regulation that doesn't say for example shippers must do X then what is implied is that shippers receivers and carriers must do X so unless otherwise stated it applies to everyone keep that in mind when you read through this don't say well I'm the ship around not the receiver it doesn't apply to me be very careful about that some specifics in the transportation operations part of it include appropriate loading and unloading operations so that you protect the food during that period of time appropriate segregation and no mangling and here again we're talking about raw to ready to eat or allergen contamination limiting glass because we're well aware of the hazards associated with that ensuring safe driving and you can see the picture the shifted load there and then washing hand washing is new it's it has not been seen before as a regulatory requirement for transportation and it landed in the law because it is already in regulations for good manufacturing practices for many for keeping safe food on the manufacturing end and some of the transportation laws were modeled after those good manufacturing practices that we already see so at hand washing being new and I have a quick poll question for you yes or no do you have a sink readily acceptable in your receiving or shipping dock okay oh my voice is coming are you can you plug your headphones in sure it says lost signal from some of the folks who are watching I'm seeing Paul yeah okay good you with a hug paintings no but I hear you fine can you hear me yes okay it looks like people can hear because I see answers to the pole both room is there's a variety of answers coming okay this better come okay the pole do you have a single inaccessible or receiving shipping dock area yes 41-percent knows so is that what you do understand okay I actually expected it to be a bit lower sinks are usually in production and processing areas but not not necessarily on the dock in the shipping area a lot of companies just don't let drivers in for security reasons even if they have to go to the bathroom but they're going to have to see a change in this area because the regulation says that sinks will have to be readily accessible so that carriers we're talking about truck drivers can wash their hands if they're going to handle the product that they're transporting so if product is not fully packaged then there's going to be a hand washing component add into the regulations that wasn't in place before and for some this is a bit of a challenge and something you think have to think about ahead of time you may have to make some structural changes or add some some plumbing to ensure that's in place okay so other requirements in transportation operations the temperatures are going to be have to be checked and maintained so it's not just a question of saying yes I'll keep the product cold it's proving that you kept the product cold there's also going to be a requirement that we maintain security or defense and it's often very easy with a full load most companies require seals either metal or plastic with numbers on them that demonstrate that you know the product was safe in transit the challenge comes when it's less than a full load in that case the recommendation and potential future requirement will be locks on trailers even for less than full loads I'll give you a bit of a story here on food defense and it's not that unusual for a trailer to come up to deliver to a food establishment and the establishment requires seals and so when they come they break the seal and open it and then you can unload the freight well a triangular arrives at a food establishment and it had no school the people at the receiving dock did the right thing they rejected the trailer that's what we're supposed to do well it wasn't more than 20 minutes later the trailer came back and it had a seal so don't you know that driver went somewhere and just applied a seal and came back this is why there's a training component necessary to the transportations and the sanitary transportation law because we need to teach people not only what to do but why we have to do it and why it makes sense and what you need to watch for when there's concerns seals are important but sometimes you also need to know the history of the seal and the history of the load there's a component in the regulation also on inspection inspections are mandatory and procedures on how you inspect are also going to have to be in though before I go further i saw a quick quick question someone asked what LTL is it stands for less than truckload full truck loads are relatively easy to handle from a security standpoint a less than a full truckload means you've had multiple stops which means it's harder to use those seals and musics more practical to use a pet and lock the last bullet on this slide is on incident management guidelines and I want to be very clear this is not in the regulation this is my recommendation keeping it's our obligation to prevent those forbidden five conditions if you think under normal operations things are under control if you don't give people guidelines on what to do in an emergency or when something changes when you have a vehicle break down an accident or an equipment breakdown it will lead to problems so I want to make sure I'm clear that last bullet is a recommendation and not a requirement so we've got all these rules as to what definitions are who's who and what's going on with transportation operations let's talk about who does what the shippers responsibility is really you understand the freight that's the number one thing because they're asking it to be transported it's their job to communicate what they're not that Freight needs to be refrigerated whether or not it needs to have specific humidity requirements and whether or not it's what we would call a TCS food it's the shippers responsibility to know that and communicate it it's also the shippers responsibility to inspect the vehicle that was provided by the carrier the shipper has to provide and wash and there's not going to be a specific rule that says how many feet away from the door the hand wash sink needs to be it readily accessible and that's a judgment call it's going to depend on how crowded your dock is and how far someone might have to walk from one place to another but hand-washing is supposed to be readily accessible the other thing the shipper has to do is prevent temperature abuse so you're getting ready to send product you're going to stage it appropriately so that loading is quick and efficient and it doesn't for example warm muffin and dock and it's also the shippers job to ensure sanitary material handling equipment so now we're talking about things like forklifts and pallet jacks and making sure that those are clean as well so the carrier they have the next set of responsibilities and they have I think the majority of responsibilities in the regulation the carrier has to provide appropriate and capable equipment well how do they know what's appropriate and capable the key to this is communication the shipper must provide specifications to the carrier that's key to success in terms of compliance with this new regulation the carrier also has to make sure that if it's a refrigerated shipment or frozen shipment that each compartment as a thermometer or a temperature recording device the carrier is going to have to retain information and provide it regarding the last three shipments for that vehicle or container and that comes directly from that issue we had with the ice cream that was in a container that previously had raw egg we're going to communicate better what was in container in the past and then the carrier also has to conduct and provide cleaning procedures for basic sanitation as well as allergens and share details of those procedures if requested or required by the super or the receiver it's a carrier's job to pre cool the equipment if it needs to be temperature controlled and to set it to the coldest requirement and again this is not a requirement that's written in the law it's a requirement and that's specified by the shipper it's the carrier's job to make sure that the temperatures are maintained and achieved as required so you can't just tell the driver to check the reading on a digital unit because digital units can fail you have to make sure that you can prove almost without a doubt that actual temperatures were maintained and demonstrated as stable and so you can see there's that whole range of temperatures pertaining to food and other products how do you know what temperature it needs to be it goes right back again to the fact that you need very clear specifications from the shipper Victoria's job is to load things appropriately and you can see a couple pictures their palates the one on the upper right is really well wrapped and the one on the lower corner is not wrapped quite as well in my opinion the one on the upper right is not a good idea because you can see what they've done if they've wrapped all the way down at the bottom which means it's going to inhibit air flow and if those are tightly packed in a shipping container or in a vehicle you're not going to get the air flow you need to maintain the temperatures that you need so we finally got the truck loaded it was clean and good shape on the way they have to demonstrate that they maintain temperatures in transit so it's not just when loading for shipping or at receiving it's also in transit so best practices show that you're going to collect as much data as possible and there's quite a few options out there technological options and I don't want to get into the details of those today because not every company can afford to do that it depends on the size of the company and the size of your customers and you need transport but best practices show that you're going to collect time and temperature data maybe even GPS data to know where your truck was and when there are transmitters that can actually share information on whether or not the doors were opened who opened them whether or not the driver stayed where they were supposed to be in terms of inappropriate territory and whether or not they stopped in a timely manner or if or if maybe the truck spent more time for some unexplained reason where you don't know where it was it would be the obligation of the carrier to explain that to the shipper and the receiver so the question I have is the law isn't specific about the information you collect or how often so how often do you think temperature data needs to be collected for these foods that require temperature control right I've loaded that in the sidebar how often do you think temperature Dayton needs to be collected for TCS foods just remand is what TC s is again Catholic it's a food that requires time and temperature control for safety okay so we have about forty five percent every two hours just twenty four percent every five minutes and thirty percent that's each dot so quite a decent spread really yeah okay and that's what go ahead yeah no go ahead cafe okay it's exactly what I expected because there isn't a rule it has to be based on risk and the shipper is going to define what the carrier must do so many companies will randomly select how often temperatures need to be checked some will say at each sub some will say every five minutes every two hours these decisions will have to be made and I'll have to be demonstrated that they're based on science are based on risk not just on what equipment you happen have or how much time you have to talk to stop and take a temperature it's a lot like the steps you take in the development of a hassock plan the decisions you make have to be supported by science and based on risk and that's the direction we're headed with this regulation so with all these things that we have to do we still have to think about the last person in the chain and that's the receiver the receiver has to provide hand-washing access so it's those same doc similar to shipping and watching access should be reasonable they have to prevent temperature of you upon receipt and they are supposed to collect and review documentation from superior with all this going on you kind of have to wonder who's going to be responsible for all this is it the individual employee is it the company is it the house of plan manager maybe or the food safety plan manager well what the regulation says at this point and keep in mind again it's not final until the end of March but the person who ensures all of this is competent supervisory personnel and there are added requirements that those involved in transportation operations are going to identify requirements and establish accountability by individuals and i really emphasize that you can hear it in my voice how each word is important the transportation operation is going to identify requirements that means they define them the law doesn't do and the transportation operations will establish accountability by individuals and I pause here you just talked about the importance of that in the United States there has been a move very clearly to hold individuals and not just companies involved when something goes wrong there's a memo that came out from the Department of Justice back in September of 2015 that said individuals are to be held responsible when corporate wrongdoing is being investigated or when corporate wrongdoing is a concern and I'm not saying this because I want to scare people I'm saying it because i want to emphasize importance of training so that everyone understands they play a role and ultimately we all are responsible for food safety so we've talked about the equipment some definitions various roles within the regulation and then finally it's fairly clear that specific written procedures are required the carrier has to have up to three written procedures one and that explains how they communicate one that explains how they clean sanitized and inspect and one that explains how they are going to ensure safety if they choose not to declare what the last three loads were for them and just a reminder that any good written procedure is going to include details on the who what when where why and the results of what happened as far as inspection procedures go I recommend you make sure they are deep table or in your paperwork don't just say we inspected say we inspected for the following and that will demonstrate that your shipper carrier or receiver has been appropriately appropriately trained as to what's a good inspection also on a mention on cleaning and sanitizing there's there's a difference between basic cleaning and in-depth queen basic cleaning might just be sweeping up the trailer that's fine but make sure you give your drivers and your carrier's the right tools you can see the brooms in that picture are notched and that's because the floors and a lot of these trailers are also notched make sure they have the tools they need if it's in depth cleaning you might take it to a washout station or a place that does that specifically for trailers as a company as a shipper or receiver you don't want to specify which washout stations are adequate evaluate them just like you wouldn't approve supplier so that you can direct the carrier where to go to ensure that it's clean and then make sure they get a wash ticket or receipt or proof that it was done correctly but the law is going to lead to a lot of written details and records that we have to have in place the sugar is the beginning of the whole process they must communicate to the carrier proof that they communicated sanitary requirements and publisher requirements and sometimes humidity as well the carrier is going to have records to demonstrate to the skipper and the receiver proof that can maintain safety according to the specification and again i just want to remind you the importance of details in your records who did what how they did it how often and what the response was weather conditions were acceptable or not and what you did next one of the biggest components i think for law is training the proposed walk right now says that there will be four hours of training required for carriers upon hire and anne's megan and put in there what i think are the key components to that training the first one is an awareness of risks and everyone's seen the classic bc and p in terms of risks that's biological chemical and physical i added two more that you might not be familiar with a CNN arc c is for customer requirements it was a lot of his hinges on what education said and they are is regulatory sometimes we forget to train our folks about the regulatory risks regulatory requirements so i encourage your training includes all those potential risk types all yours don't have to have complete hence of training but they have to understand what hath is and what does food safety plan is and how important it cuz safeties regulate towards the point toward protecting the freight they need to be trained on basic sanitation and environmental controls how to communicate what specifically responsibilities are and how to handle incidents should they occur so the training compartment component i think is essential and it only says upon hire or as needed in my opinion it for not just the new ones and not just the ones that handle exposed food i think there's a need to improve training in transportation in general so finally just some recommendations as to what we need to do clarify your requirements be very clear in your specifications as a / or a receiver make sure you declare which foods might require time and tell for safety that's those TCS foods hey the expectations we have for transportation and then get agreement in writing because we're headed toward more of a regulatory environment for transportation those the contracts are going to become more and more important and then consider only using certified carriers or companies and the global food safety initiative which with which we are all probably very familiar has multiple auditing schemes and there are carriers that are becoming certified not just no importa good apple point thinking about how you might develop the Mules written for wimps make sure you can Doug or obtain training and improve your water keeping just emphasizing the basics you can see I put here the four cornerstones of food safety these are the ultimate basics keep things clean keep things separated keep them cold and cook them properly of those four things three out of four pertain to transport hopefully we're not cooking our food in our vehicles but it emphasizes the importance of transport as a key element of the supply chain that we really haven't looked at closely in the past so I know we have some questions I want to make sure and follow up with one comment because every training event I try to emphasize this and that's what i want to thank you and i want you to remember the importance of what you do just for a minute think about the perfect cup of coffee or the perfect space or the perfect hamburger or the perfect french fries whatever it is that you like think about how that makes you feel it makes your day it makes an event it makes things so much better for people we have the ability to contribute to that we can make people happy healthy well-fed or frankly we can kill them huge contrast straight but we forget that because it gets to be an a very much a manufacturing and by and it's day-to-day work and we forget the importance of what we do so I want to thank you what you do thank you for what you do remind you how important it is and encourage you to focus more now on the connections between the steps in the food supply chain okay fantastic cafe you can stop sharing your slides now that was really excellent an excellent primer and it is a missing link that had to come you know food food companies food manufacturer packaging then obviously transport is it's a big change over a lot of companies do you think it would be a big change I do think so because I think the challenges of crispity halo drug keeping is going to be something that's going to take a lot of effort and um as we've seen there haven't been ill nas's but when the people start doubting us and stop trusting the industry we've got to do better so it's going to come down to I think the record keeping and the training haha and do you think then obviously it is the availability like you said of gfs I benchmark standards sqf have got one BR cifs do you think if you implement one of those then you will be close to meeting the requirements that you've just laid out closer Clowe yeah and keep in mind that all of those schemes say you have to follow the laws of the you know domestic place where you operate so you're going to have to choke legal implications okay take off time for a few questions cafe just just one comment when it comes to gfs I quite a few manufacturers are certified I only know of one trucking company that's done it so far and we wrote a hassle plan and it was the simplest flowchart you ever saw it said pick up food drive drop off food but there's a lot of more detail in it when you look at it without without though well there's a lot of questions I hope you're not going out tonight anywhere Kathy okay I'll try to pick through a few can Pamela's us can the receiver request the temperature record from the carrier in receiving definitely they can and they should write okay that's easy no Tony on Robinson how do you manage LTL appropriately how do you manage OLTL appropriately yeah right now everyone struggles with that because it's not easy to use seals or multiple seals and I think we're at a stage where we just have to use baby steps first thing for l.t.l.s let's at least start using padlocks if not seals ok go device Lena is asking what about e-commerce companies when product is shipped to customers is the only thing visible refer referring to this yeah that's a great question as far as i understand that does not apply if it goes from a factory environment directly to a consumer okay or if I like that okay Simeon in meat industry transportation of vacuumed meat pieces are enclosed in a car park is this allowed concerning the fact that some vacuums are not appropriately sealed well that's a another haha well they should be sure to hit the route car and the root cause is not the transpose a is the ceiling of the meat right keep in mind that this lies FDA so in the United States it does not apply to meat and poultry cuz they're regulated by FSIS or the food safety inspections okay Brent's asking will there be required documentation to show when crossing state borders no I do not think so okay for bulk liquid shipments how do we ensure sanitizing of the vessel we found it we find our trailer liners cannot have a wash at high enough temperatures to be classified as sanitizing um this is a case where you're going to have to look at the specification from the shipper and the receiver as to how clean is clean and what their requirements are if you're transporting the same food type repeatedly you can get this in writing that for example there's not an allergen concern and then between the chipper the carrier and the receiving you need agreed specifications the law is not going to tell you what to do you have to avoid me from in five yeah I think one of the big issues will be where transportation companies that are not dedicated to food you know where only a proportion of their business is food they're going to be pretty much out of the game with shipping food ugly I think that's quite possible especially with the training component for drivers and I'm hoping we're gonna head toward a situation where truck driving school also has a sanitary truck driving component yeah but I'd probably not going to invest in that if if only let's say ten percent of their businesses food might not be worth it Roberto does the regulation apply to food packaging materials like plastic closures at this time I don't think so awesome okay Martine has just made a point how common are certified transporters in the US in my country EU we only have five certified transporters to choose between the thing you said that before it India only one yeah I do quite a bit of gfs I training and consulting and I don't know how many transport companies are certified but I know I've only dealt with one myself yeah so transport companies that good do go down that road route route quickly drive down that road quickly then they could good business to teach their face Jeff is saying if they stray from enforcing food safety risk and concentrate on quality this will be an overbearing law of being overbearing glory Thanks that's an interesting comment because the regulation includes things like decomposed and that's in some cases of food safety concern in some cases it's a quality concern we're just gonna have to watch to see how this turns out through the enforcement stage and what happens between disputes lawyers and regulations yeah okay Kathy Brent's asking do these schemes and I think it means gfa GFSI schemes have specific programs for transportation we mentioned that before ifs at PRC and sqf all of storage logistics distribution specific standards Corey's asking the definition of food handling by drivers is the definition of food handling by drivers okay food handling itself isn't defined food is defined and fully packaged food is defined so if a driver is going to handle meaning pick up move whatever or touch boxes or plastic containers or anything that are vented it's not fully packaged and so the rules would apply to them and they need to practice hand washing okay dokay we've mentioned before that packaging isn't included so far he helps us game what about loading finished full packed God's on truck floor without pallets if there is no risk of tilting or disorder again fully packaged things aren't gonna fall under the law and for those of you who are thinking yay hooray this doesn't apply to me I still look at what the law says because it's gonna define best practices moving forward okay who teaches the four-hour training Vicki asks me ah-choo oh yeah we can put into contact with Kathy if you want the forward our training that's fine drop me alone does hand-washing apply when receiving ready to eat bulk product case packs products arrives in close cases and no restocking is required again if it's only enclosed the hand-washing might not imply just makes turn is fully enclosed okay uh when will this take effect this new regulation the regulation is supposed to be final March 31st with enforcement no earlier than 60 days after that usually there's a phased-in enforcement so we'll have to read what it says in the final rule right and so so the B inspectors going auditing against this yeah god I doubt um the FDA is spread thin and taxed with a lot of requirements I don't think they're going to put extra inspectors out in the field but it's going to enable them that if they happen to see something they can better manage it under the law I don't see a lot of money being put in this direction I'll put it that way okay hmm that's interesting the truffles exempted transportation on international waters can you comment on how fsvp will need to work best with shipping fsvp meaning food safety verification program or the voluntary programs for imports I'm assuming again this particular law that we're talking about today only applies to ground transport but it's in place as soon as the stuff hits the ground in the United States so if it's carried by ships say in transit overseas it comes to the United States when it's unloaded onto the dock to a truck or to a railcar now the law is going to apply okay Oh what about a case of bananas Kathy what about a case of bananas what we're going to do with that hugs are not 12 it's a raw egg a cultural commodity ha right okay David asking can we get a two hour version no you've got to well you might have to go twice if you have a two hour version it's four hours oh right sorry supply I think I think we've gone past the hour Cathy you've got through quite a few questions if there is some well there will be when we want a pic through because it Scrolls way down here and there will be some what other questions are you happy to maybe I do some of them via correspondence if there is any you know a possible okie dokie well welcome to share my email address if you need to will do right Kathy thank you very much for today on behalf of myself and the ifs qn and every all the attendees today and those that will see this recording in the future it's been great yeah really enjoyed your first session right thanks for having me yeah hope it won't be the last oh ok thanks Kathy ladies and gents what we do now is we give you your certificate last year last week you brought the system that many of you it was a lot logged on last week and it was that many of you trying to get the cific at once the website exploded and crashed so take your time if it crashes don't worry we do send an email after today within 24 hours i'll send you all an email with the recording the slides the certificate everything so don't worry if you don't get it today you will get it by email but for now I'll load it in the sidebar and you can try and get it next week as a savers got Cornelius back with us Cornelius is from AIB was a global innovation manager at aib and he's going to be discussing the foreign supplier verification program for food importers so again we're still on FISMA whether this these laws relate to you these regulations are not I'm sure you'll agree today's presentation by cathy is great for anybody in the food chain where the food pack in storage logistics transport whether the regulation applies are not so thank you tendons today it's been a great session please register for next a lot farther senior as I say every week happy friday to you it's the best day of the week have a food-safe day and have a lovely weekend i'll see you next week take care bye

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