FSMA’s Sanitary Transportation Rule assumes that all of us transporting food know and use established best practices. Working in the fresh produce transportation industry, we do see a growing interest among fresh produce haulers about what safe food transportation should look like in their businesses. There are some carriers that still remain unclear about what these guidelines should mean for their companies.
For the companies that have implemented a transportation food safety plan around these best practices, they are headed in the right direction and should be fairly compliant with FSMA. But because food safety requires us to be proactive, preventative, and very practical, there may be a few things we can add to our programs to be completely compliant with the law.
You may be thinking, If our current best practices, even those now being revised and improved, are what the industry’s experts think will give us the best ways to keep food safe when we transport food, then why do we need to go beyond our best and make them better?
What does bombproofing do to our protocols, and why do we need this added bolstering to what already seems to be working for us?
Here’s a few of the words and phrases that define bombproof: Safe, sturdy, extremely durable and/or resistant to dangerous forces.
People want to bombproof things for a variety of reasons. They don’t want something to get broken or ruined because, when something gets trashed, it costs money and time to get it repaired or replaced. And sometimes, neither replacement or repair are an option.
This applies to our bodies, our careers, our business operations and systems, even our company brands. I always think of horses when someone mentions the word bombproof. A bombproof horse is the only kind of horse I want to ride. At my age? Yep, I need safe and resistant to anything and everything that could possibly make my horse spook, bolt, buck or rear.
Bombproofed best practices should be the only protocols that we are willing to use to make sure our transportation programs keep food safe.
So where do we start? If we are already using best practices and have them not only written into our transportation food safety plans (you have one, right?) then what else can we do to make sure there are no gaps in our protocols? Where are we most vulnerable?
The obvious focus that usually gets the most immediate attention is upon the practices that are not getting done, things we are not yet doing to prevent food from becoming unsafe during transportation. The good thing about how the FDA’s transportation rule was written is that it provides a framework or structure that can help companies implement safe food protocols.
When I wrote a plan for our carriers, I essentially used the rule, section by section, so that I didn’t miss any requirement that the FDA saw as necessary to include in a complete food safety plan.
You can do the same thing. Go through the rule and list the expectations. Then ask yourself and/or your team, “Is there anything missing from our plan that should be included to ensure that we are in full compliance?” It’s basically checking for gaps in how you operate, maintain your equipment, support and train your people, and of course, your documentation process.
But while these obvious areas sort of stick out, it’s not usually these things that trip us up. In my experience (nearing 25 years now) my biggest mistakes have happened when I’ve been the most comfortable. I’m doing things right, but confidence fades somewhat towards complacency, and all of a sudden, big problems.
Transportation is very much like horses. You just never know when something can go sideways, and when it does, situations get ugly fast.
It’s not the flapping tarp or loud tractors or whatever unusual sights or sounds that suddenly startle a bombproof horse. It’s weird stuff, like someone with a strange hat walking along a fence or a piece of machinery that gets moved from one place to another.
Loading fresh produce is similar. It’s the ‘normal’ that shifts slightly creating an entirely different situation from the usual. It could be a change in personnel, someone new or different who dispatches differently, or customer that is shipping from a new or different loading facility, or a new or different loading or delivery protocol that requires a different transportation procedure.
Can you see the culprit? It’s the ‘new or different’ circumstance that makes us vulnerable to problems. A sudden or unanticipated change can have a negative affect on our best practices and ultimately our FSMA compliance.
But, here’s the rub. Transportation, particularly fresh produce transportation, rarely operates in a perfect world. We need to bombproof our best practices so that even if something changes, we can ride it out and end up keeping food safe while it is under our care and control.
The most common sense approach to anticipating (being proactive) and managing (being preventative) these likely problems is to incorporate a few ‘What if’s’ into our protocols.
The picture I used today for this blog is of a poster that’s been hanging next to my desk for a long time. Titled ‘Loading Refrigerated Trailers’ and dated 2002, this UC Davis resource, written a while ago but still very relevant, presents several of the most critical best practices that all of us transporting fresh produce should know and use in our fresh produce shipments.
Each of the protocols on this poster are common and correct best practices. While it’s not complete in terms of FSMA’s Sanitary Transportation Rule, for the most part, adhering to these guidelines would help keep a company compliant.
But each one of them could be bomb-proofed by adding a few ‘What if’s’ to take them from a guideline to a compliant protocol. Numbers 1 and 3 are perfect examples of questions that arise from a seemingly straightforward protocol.
Number 1: Only load cool trailers
Seems practical and self explanatory, but what if the trailer has been parked in 90 degree heat and needs more than the shipper’s recommended pre cool period? A new driver may not understand that the shipper’s requirement may be inadequate to get the trailer properly cooled for its product.
What if the shipper hasn’t given a specific pre cool time or temperature? Shippers are not all equally proactive so the driver has to make the decision about the pre cool step.
Or, what if the shipper has specified a pre cool time and temperature, but so has the receiving customer? Whose protocol will the driver use?
Number 3: Do not load if trailer is damaged, has a bad odor, or is not clean.
What if the driver is unsure whether the damage in the trailer is something that needs immediate repair or can wait for a service at the home base?
What if the trailer is damaged during loading?
What if the carrier’s best customer damages the trailer and the driver is unsure about how best to handle the problem?
What if the loader sees or smells a problem but the customer’s QA person ‘passes’ the inspection and insists on loading the trailer? What should the loader and/or driver do?
What if the driver has arrived with a clean trailer but the forklift loading his or her trailer is also loading one in the next bay that is visible filthy? What protocols does that driver follow?
A great best practices resources that the International Refrigerated Transportation Association (IRTA) created a few years ago include thirteen sections and over fifty best practices. That’s a lot of information that if incorporated into a company’s food safety plan, routinely monitored and correctly documented, these protocols should be adequate to keep a company FSMA compliant.
But these are guidelines, meaning that for companies that are transporting specialized freight such as fresh produce, it would be worth going doing a bit of bombproofing its best practices. Using the simple ‘What if’ test, companies can better support their drivers by incorporating common sense protocols for those pesky but typical transportation scenarios that will arise and jeopardize a company’s FSMA compliance.
Bombproofing takes a little more effort but it goes a long way to show that we understand FSMA’s goal of being practice, preventative and practical.