On April 6, the second phase of Food Safety Modernization Act (FSMA) enforcement came into effect, requiring small carriers with less than $500,000 in annual revenues (or fewer than 50 employees) to comply with the requirements.

Larger carriers and shippers – and anyone else involved in the transportation of food products – were required to comply last April. But Lindsay Glass, training manager with Dartmouth, N.S.-based training firm Iron Apple, feels there are still many companies involved in the transportation of food that are not up to speed on the new rules, aimed at improving food safety throughout the supply chain.

“The industry wasn’t prepared for it at all,” Glass said in an interview with Truck News. “A lot of the companies, especially the larger ones, were doing a lot of what was required already.”

But even carriers that were already safely handling food products in accordance with the FSMA, may not be aware of new training and documentation requirements the Act ushered in.

“A lot of companies didn’t have written procedures on how they’re going to clean their vehicles and trailers and equipment and how to maintain them,” she said. “Training was the biggest one. You have to train everyone associated with the movement of food.”

This includes truck drivers, and anyone else in the company that is required to make decisions related to that product, including whether to accept or reject a shipment.

“To our knowledge, there are still a lot of carriers that are not in compliance yet,” Glass said.

She blames this on a lack of Food and Drug Administration (FDA) enforcement of the Act, and worries that the carrier community may be caught off-guard if an expensive example is made of a non-compliant fleet.

“A lot of people in transportation are bogged down with a lot of regulations,” she reasoned. “They kind of wait until something happens, then say, ‘Okay, we’ve got to do this.’ Transportation companies put it on the back burner.”

Iron Apple offers online courses that meet the FSMA requirements, and issues certificates upon completion that can be provided to the FDA in the event of an audit or inspection.

“If you take our training, you meet all the requirements for training,” Glass explained.

Brian Belcher, chief operating officer and co-founder of document and workflow management system LoadDocs, says key takeaways from the FSMA include the following:
• Carriers must provide shippers with “three prior” documents – a document that tells the shipper the three previous foods that were in the truck. “If milk is about to go into the tanker, there better not have been crude oil in there yesterday,” Belcher said.
• Carriers must provide shippers with “wash tickets,” which show the truck has been cleaned since the prior load.
• The reefer must have a thermometer that reflects temperature accurately. The shippers must verify proper pre-cooling before loading, and upon delivery, the carrier must demonstrate to the shipper and receiver (upon request) that the food was transported under acceptable temperature conditions.
• All FSMA-required documentation must be kept for 12 months.
• If FDA requests the documentation, it must be supplied within 24 hours.
• Records must be kept in either original, or electronic form.

Chris Lee, vice-president of engineering for Great Dane Trailers, said the FSMA has brought heightened interest to food safety and the prevention of bacterial growth in refrigerated trailers. Great Dane’s answer to this is the Microban antimicrobrial trailer liner, designed with silver ion antibacterial technology. It’s the same technology that’s used on toilet seats and other surfaces that are prime areas for bacterial growth.

“They have this chemical silver phosphate infused into the surface of the hard plastic during the manufacturing process so it’s permanent and doesn’t get rubbed off,” Lee explained. “That solution penetrates the bacteria and inhibits its ability to be reproduced.”

However, he warned it’s not a substitute to regular cleaning.

“You still need to wash out the trailers,” he stressed. “But having this antimicrobial technology in the liner basically inhibits the microbial growth.”

Great Dane is the only refrigerated trailer manufacturer currently using the technology in its linings, Lee said. It does add manufacturing costs, but Lee said the company has absorbed the increase rather than raising the costs of its refrigerated trailers with the liner.

George Cobham Jr., vice-president of sales and marketing at Glasvan Great Dane, said it has proven popular with Canadian fleets.

“Some of our fleet customers and leasing customers are very interested in Microban,” he said. “It helps them stand out to shippers by offering a way to protect the integrity of the freight they haul. They ask for it by name during the quotation process.”

Another way to assure shippers and receivers that their product is being transported safely, and in accordance with FSMA requirements, is to provide greater visibility into the temperature of the product during transport.

Colin Warkentin is vice-president of cold chain solutions at Digi International. The company’s products offer a single view to the shipper, receiver, and carrier, of a load or product’s temperature throughout the entire distribution chain. Small, quarter-sized sensors half an inch in thickness are placed inside the trailer and on specific product.

“We have gateways on the trailers that pick up by Bluetooth the sensors and through the Telus network transmit data back in real-time,” Warkentin explained.

It provides better accuracy than reefer telematics, he added, since the sensors are placed directly onto product. This, said Warkentin, marries the needs of transporters with those of customers, who are demanding more specific temperature control information. For example, the shipper of a single pallet of product in a refrigerated LTL load can be assured their product remained within an acceptable temperature range the entire time.

The technology is an effective way to comply with FSMA requirements, because it is automated and eliminates the likelihood of operator error.

“What happened is, carriers had to put processes in place. But those processes in a lot of cases were manual and not very cost-effective or scalable,” Warkentin said of FSMA requirements. “What we’re talking about is making it operationally effective, so it’s not a burden to their system. It’s one thing to meet the requirements, and another to do it efficiently and get value out of it.”

It’s also a good way to reduce rejections at the loading dock, with easy access to proof that the correct temperature was maintained while the cargo was in the carrier’s care.

“What happens for the carrier is, they are guilty until they prove themselves innocent,” Warkentin said, when disputes arise at the receiver. “So, they’re scrambling around, pulling documents together, downloading reefer information.”

Real-time failure alerts are also handy, especially when trailers are pre-loaded the night before delivery. If a reefer failure occurs during the night, the appropriate people will instantly be notified, rather than arriving in the morning to a spoiled load.