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Get Real and Get Your Transportation FSMA Compliant

November 28, 2017

 

We both knew it wasn’t true.  Ella may have seen, but she was not about to believe.

 

“Mom, your cycling jacket makes it look like you have abs!”

 

Yeah, right.  Wish I did, cool to think it looks like it's true, and probably not going to happen.

 

The funny thing about this coat is that while it is one of my favorites, I had never noticed the details that did in fact make it look like I am pretty darned toned.  The truth is...eh, not so much.

 

We went off that morning on our ride through South Monterey County, and as I rode past the vineyards and harvested onions, I kept thinking about how this exchange at home was very much like compliance with food safety rules in the produce transportation industry.

 

The Sanitary Transportation Rule has been official since April 2016, and enforceable since April of this year.  And yet, as I check in with people (mostly carriers and shippers) about how their compliance is coming along, I still get questions that clearly indicate that not only are they not working on it, but worse, they don’t even know what it actually now requires them to do.

 

And then there are the companies that tell me it doesn’t apply to them for some reason.  Or that their customers have not required it. So until then, it is not a priority, and not getting done.

 

But the scariest situations are those that are similar to my JL Velo cycling jacket.  Things are not really as they seem.  Companies have some sort of plan, or system of documentation.  However, ‘unzip’ their plans and one can see that the company actually doesn’t have a complete plan that is aligned at all with FSMA’s rule on food transportation.  

 

Back to my jacket, honestly, I may be on the other side of 50, but that does not mean that I can’t work out and stay fit.  The truth is, it takes time, effort and sheer discipline to be toned, especially at my age.  It all boils down to a question that only I can answer:

 

Am I really serious about my health?

 

Can I resist a warm slice of Costco’s Country French bread, maybe followed by a Sierra Nevada Celebration Ale?  See? It’s already getting complicated.  It’s bad enough to forego good food and drink, but to add in the physical requirement of rising at 4 AM to ride my bike...Oh gosh, not sure at all now about being toned.  Still thinking about it...Maybe I’ll just wear the jacket everywhere.

 

But I have the luxury (at least for now) of deciding to do what is necessary or not.  No one has published a rule that requires me to be fit, and a failure at doing so will not result in serious legal consequences.

 

A carrier does not have this flexibility. The rule is the reality, and the people who can enforce it have already said that they plan to do so with whatever means necessary to make it happen.  

 

For example (one of many) the FDA has posted the following.

 

“FDA will carry out some inspections, and the Department of Transportation, under the 2005 SFTA, will also establish procedures for transportation safety inspections to be conducted by DOT or state personnel. FDA maintains its ability to take enforcement action when agency efforts to work with a company fail to achieve compliance, but promoting a strong food safety culture is FDA’s first priority.”

 

Last week the FDA published the Small Entity Compliance Guide for industry members engaged in the transportation of food.  Even if a company does not fall within the scope of ‘Small Entity” as defined by the FDA, the information contained in the guide is a valuable resource and tool in understanding what exactly the FDA is try to achieve in this rule.  

 

For example, the question and answer format of the FDA’s guide does a great job of breaking down the required elements of the regulation so that a person writing a compliance plan for their company can use the questions to structure their document.  Not only would this help in getting the plan written, but just as important, using the FDA’s questions as a guide will help make sure that nothing important is missed or omitted. That’s because we all need to remember that the compliance coin has two sides:  Get it done on the one hand, and peace of mind on the other.

 

As of today, the rule is official and compliance is required, but we are still in the ‘education’ phase of enforcement, meaning there is time for companies who are a ‘party’ under the rule to get proactive and start getting their procedures written and adequately communicated.  They need to make sure they have in place a system of documentation and record keeping, also required under the rule.

 

I do understand that becoming compliant with this set of regulations is like many things in life.  We all have people telling us that we have to do certain things, but often what is most helpful is knowing how to get those things done. What does compliance really look like?

 

Ask the questions, do the homework, and get help if you need it.  Most importantly, do not choose to cover up the reality that maybe your company is not prepared for an FDA inspector to darken your doors and start asking for your plan.  

 

Here is that latest FDA resource for compliance, now get going.  Time is of the essence.

 

There are lots of people that can help you.  We are one of them.   

 

After a year and a half of trying different ways to help people get this done, well, we still don’t know everything.  But we definitely can give you direction and some tried and true suggestions.

 

Call or send us an email to get started.  

 

 

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