FSMA implementation & compliance
Food safety remains at the heart of FSMA with documentation being required for compliance.
The Food Safety Modernization Act (FSMA) was signed into law in January 2011 as a means to give the Food and Drug Administration (FDA) authority to regulate the way food is grown, harvested and processed.
Within FSMA includes regulations specific to the sanitary transportation of farm-to-table food processing. That means motor carriers are specifically held responsible with regards to prevention practices during transportation. These food safety risks include failure to adequately clean vehicles between loads; failure to protect food; and failure to properly refrigerate throughout the trailer. This rule applies to all shippers, loaders, carriers and receivers.
Specific to the trucking industry, the regulations establish requirements for four key areas—vehicles and transportation equipment, transportation operations, training and records. Under the regulations, the design and maintenance of equipment must be kept up to date to ensure that transported food does not become unsafe for consumption at any time. Training of carriers and utilizing best practices and documentation is required under the act throughout the carrier and shipper transport process, and lastly, records must be kept as written records of procedure. The question for motor carriers is how the process of records and maintenance will be examined and how fines are enforced.
In addition, the FDA has six additional rules that are the foundation for prevention and are included within the FSMA. They are: (1) Preventive controls requirements for human food, (2) Preventive controls requirements for animal food, (3) Standards for produce safety, (4) Foreign Supplier Verification Program for importers, which requires importers to take steps to help ensure that imported human and animal food is as safe as that which is produced domestically, (5) Accredited third-party certification, also known as certification bodies, to conduct food safety audits and issue certifications of foreign facilities and the foods they produce for humans and animals, and (6) Focused mitigation strategies to prevent intentional adulteration aimed at causing large-scale public health harm.
The right documentation and use of data
Food safety remains at the heart of FSMA with documentation being required for compliance. Since documentation is critical, the widespread adoption of recently mandated Electronic Logging Devices (ELD) will help significantly.
FSMA compliance may create new challenges on shippers, carriers and receivers trying to maintain standards of food products during transport, loading and delivery processes. Shippers will be required to document and communicate their food safety requirements to carriers in areas of equipment, operations and training. Failure to provide documentation of the compliance can result in fines, cargo claims and criminal sanctions.
This is where the ELD conversation comes into play, as not all ELD systems are created equal. Now that the ELD mandate is official, fleet managers are being forced to make an important initial decision—Do I view the ELD mandate as a “necessary evil” and spend the least amount to meet compliance, or do I go “all in” and realize the true value of the data it provides?
Thinking strategically about the data fleets need to provide proper documentation for FSMA is critical, but the right ELD goes well beyond this spectrum and can help manage the fleet’s overall performance, including driver behaviors and vehicle lifecycle options. However, it can also assist with reefer trailer monitoring to help with FSMA compliance. Organizations must make a thorough and methodic “due diligence” approach to their ELD decision.
More than just the ELD
In addition to the ELD, motor carriers should focus on the equipment design and specification phase of their truck procurement strategies.
Working with a consultative partner during specifications, with details such as ribbed flooring in refrigerated trailers that make it easier to clean, for example, can ease the burden of compliance and operations. But, data extracted in the ELD and other aspects of operations can really pay off, including the identification of costly expenditures in maintenance and repair.
By using data analytics, motor carriers can monitor every aspect of data, including FSMA, to help determine the right lifecycle of each truck, compliance and documentation. Doing so, fleets will ensure a stronger compliance record with FSMA, and will realize better bottom line savings that can be utilized for critical business expansion opportunities or driver recruitment programs.