NASHVILLE, Tenn. -- The impending US Food Safety Modernization Act (FSMA) will have major implications for Canadian refrigerated trucking companies that haul in or out of the US, as well as Canadian food companies that export product there.
During a presentation to the Technology & Maintenance Council here this morning, Bud Rodowick, manager, fleet performance with Thermo King, said carriers should be communicating with their customers to find out how they’ll be affected by the sweeping legislation.
The FSMA, described by Rodowick as “the most expansive changes in food safety legislation since 1938,” was enacted Jan. 4, 2011, but sat idle until after the US election. Now, lawmakers are acting on the legislation and putting it into effect.
“This is a huge act, that’s very complex and enormous in size,” Rodowick warned, adding it gives the Food and Drug Administration “sweeping new powers,” including the ability to send people to prison for felonies related to the careless or negligent handling of food.
Under the new rules, food companies will be required to demonstrate care of their products through the entire supply chain, or from “field to fork.” This, of course, extends to the transportation of their products.
“You’re a big part of that, but you just haven’t been made aware of it,” Rodowick said to trucking company executives and maintenance managers in attendance.
There are 450 sections in the act, and four key ones impact transportation providers, Rodowick said. These sections include: preventative controls and hazard analysis, traceability, sanitary transportation of food and the intentional adulteration of food.
To comply with the regulations, food companies will have to produce a written food safety plan, specific to each facility, outlining hazard analysis, preventative controls, monitoring procedures, corrective action procedures, verification procedures and a recall plan. They’ll be required to retain all records related to such a plan for two years, and to provide them to FDA upon request.
“This is going to be burdensome,” Rodowick said. “This is a great opportunity for you to be talking to the food facilities you haul for and saying ‘What does your preventative control plan look like and am I going to be a part of that?”
The new regulations also will require a product tracing system that can be used to track and trace all food products that are produced in, or imported into, the US. Rodowick said the requirements are likely to include a temperature traceability aspect, meaning the FDA will want to see proof that food was transported at the proper temperature throughout its journey.
While it will be up to food manufacturers and shippers to comply with the new FSMA requirements, there’s no doubt trucking companies will be a vital part of any compliance plan, Rodowick warned.
“FSMA is evolving, and it’s important to understand how compliance requirements will affect your customers and you,” he said. He urged carriers to “Visit with your food facility customers and understand how they intend to be in compliance with those requirements and what those requirements mean to you.”
A final rule is expected to be published in 2014, with full enforcement in place by 2015.
It’s likely shippers will begin insisting on more transparency and control over the transportation of their products, which could bring new costs on trucking companies if they have to upgrade their fleets to provide more visibility and remote control over reefer temperatures.
“If I was a fleet, I would want to grasp and clearly understand what the intentions of my shippers are and based on those intentions, I would be sitting down to figure out what technologies can we retrofit and what can we buy new? Let’s get prepared for this so we can transition to this in the next year,” Rodowick said. “I’m trying to champion you guys to start talking about it now so there’s no sticker shock.”
Lori Coleman of Gordon Food Services moderated the discussion, and added that her fleet will be leaning heavily on trailer manufacturers to come to the table with solutions. For instance, she predicted the rules will eventually require trailer doors to remain locked at all times while parked and in transit, and a simple padlock isn’t an adequate solution. She also suggested trailers will need to come with better options for compartmentalizing product from various shippers.