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Fear 'No Fear'!

Having no fear about some things can be really dangerous.

Perspective really makes a difference when it comes to taking a risk.

For example, consider these bulls. From a distance, they don’t look that big, and for sure, they don’t look mean and belligerent as they stand placidly with the rest of the herd.

But oh can they run when they see something interesting at the other end of the arena! I’ve seen it happen a few times when someone starts out at a brisk jog and ends up in the sprint of their life. These bulls can move at lightning speed and are trained for competition. And their competitor, a professional bull fighter, is a real person, so seeing someone make a run for it is just too much for a rodeo bull to resist.

Here’s another quick example of how something beautiful can turn scary and often disastrous.

We live in the Monterey Bay area where the ocean and beach are gorgeous. And one would think that the pounding surf would be sufficient to alert people to the potential hazard of getting too close to the action.

But no.

There are even signs posted in and around the tide pools about the speed in which the calm, serene surf can turn furious in a moment's notice, often without visible warning, easily able to snatch an unsuspecting person off the rocks and into the ocean.

I get it. The spray off the waves is invigorating, and something about being so close to something so massive and mighty can be oddly alluring.

But very dangerous. Sadly dangerous and life threatening.

In some situations, it is probably smarter to fear a ‘no fear’ attitude. It doesn’t matter how calm, or simple, or non-threatening something might appear. It’s just plain common sense to understand the reality of things and stay safe and secure.

As I watched a person run across the arena in front of those crazy bulls last week it reminded me of how I see people handling their new obligations and responsibilities under the FDA’s Sanitary Transportation Rule.

Three months ago this rule became official. Industry stakeholders, particularly those specifically named in the rule, know that there is a rule that may apply to them, but not being sure, many are ignoring it’s existence and the likelihood that they must comply with it.

It’s been interesting to hear the reasons that companies are delaying their compliance efforts, both in the produce and the carrier industries. Here’s a short list, with a few responses.

“We’re not hearing anything yet that we need to get on this.”

(Interesting. It’s been published for over a year and enforceable since April 2017. Your produce customers aren’t asking you if you are compliant? Has your insurance carrier been curious? Are you subscribed to emails alerting you to governmental updates on this rule’s requirements?)

“Our customers know that we are already using best practices.”

(They know They have come to the dock and checked your equipment? They are assuming this because your deliveries have gone well? Do they know that sometimes you broker out the load they think you are hauling, and you might not be sure about that carrier’s best practices?)

“How often is it that a truck really is THE contributing factor to an illness outbreak?”

(This no one knows for sure, either way. But the rule does not say, “Until we know for sure, you don’t have to be compliant.”)

“Our trailers are clean... Our trailers are new... We get washouts.”

(This will get interesting in the near future. But are your conclusions based on visible inspections or other sensory methods? One guy told me that when he is aware of ‘off odors’ he immediately takes care of the problem. this his ‘test’ about whether his trailer is clean?)

“Compliance is too expensive at this time.”

(It is expensive. We think so too. But the costs of not being compliant are too high.)

“We don’t haul fresh produce very often.”

(Well, that’s not part of the rule. Maybe you should decide on a ‘no fresh produce’ policy, and to be on the safe side, no food.)

“Our carriers know what we expect.”

(I’m sure they do, at least the owners. But from experience, I can tell you that drivers, and often the dispatchers, don’t know how to pulp product (and often are not sure what the pulp temps should be,) or understand the importance of where to place a temperature monitoring device, or...or…)

Hopefully you can see my point. And if you are working on this, I don’t even know you and I am proud of you! Excellent decision!

But for those of you who are not, I will make two comments.

First, the FDA has said that this year is more about educating the stakeholders and making enforcement a ‘soft’ enforcement. This means that they are giving you the opportunity to get going, but please start so that by 2018, or maybe if you somehow get pulled into a food safety issue, you are prepared and confidently compliant.

Second, I’ll use another ‘non food safety’ example of a perspective you may want to consider. When my children were small, they were just short of perfect. But from time to time, they would be naughty, and ignore my rules.

Like not running across the street without looking. I am probably a mean mom, but this scared me, so I opted for guerilla tactics instead of soft gloves. I did not say, “Darling, the street is full of danger, and if you don’t listen to Mommy, you will get an owie.”

Are you kidding?? I said, “You run out there where drivers are not looking for children and you will be hit and get very hurt or die!!”

So please listen to me. Stop ignoring the obvious, serious threat to your business and fear ‘no fear.’

Get compliant!

#compliance #foodsafety #FSMA

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