Our April FSMA Fridays session with Dr. David Acheson of The Acheson Group explored multiple facets of the Sanitary Transportation Rule, which took effect on April 6th. The session was facilitated by Dave Detweiler, VP of Sales for SafetyChain, and included discussion of pre-submitted questions. Read on for highlights of the discussion of this FDA rule. Our previous blog post includes additional highlights from this FSMA Fridays session.
Planes, Ships, Trucks, Trains…What Kind of Transport Does the Rule Actually Impact?
The session included a discussion of the rule and its impact on the movement of food within the United States—that is, in rail cars and in trucks (if you're moving food in the United States on a ship, the rule doesn't apply). If food arrives from overseas on a ship or an airplane and is then transferred to a truck or a rail car, then it becomes impacted by the rule when it's in the rail car, and when it's being moved in the United States. One of the exceptions Dr. Acheson pointed out in that context was if food was arriving in the Port of Los Angeles and was being trucked up to Canada, sealed, not going into commerce within the United States, that would be exempt. The Sanitary Transportation Rule impacts all transport linked to trucks and rail cars moving in the United States that is destined for United States manufacturing, processing, or consumption.
Shipper, Loader, Carrier, Receiver: Controlling Risk While Transporting Food
Dave Detweiler asked Dr. Acheson to provide his insight on companies that are transporting their own product back and forth to distribution centers, and whether that adds some complexity with this rule, time and temperature, and additional oversight. Dr. Acheson said that it does add complexity, and indicated that he feels that one of the challenges is for operators to ask themselves whether what they are doing is creating a potential risk that the FDA is going to expect them to control: “The final rule broke the whole system down into four categories. You could be a shipper of the food, a loader of the food, a carrier, or a receiver. Some entities may be doing, frankly, all four.” He went on to say, “In simple terms, my view of this is that the shipper is the one who has the biggest burden. They're the ones that really need to be paying attention to setting the controls and understanding the risks with regard to food.”
According to Dr. Acheson, the shipper can dictate to the carrier what criteria must be met when moving time/temperature-sensitive product from point A to point B and all that is done through written agreements, which become part of the shipper’s compliance records for the relationship with the carrier.
More Questions, More Perspectives
April's FSMA Friday conversation also explored exceptions and waivers. For the discussion about this facet of the rule, access the recording and also learn what Dr. Acheson had to say about the following:
- If I am a shipper, am I required to see the agreement the receiver has with the carrier?
- Some products are shipped refrigerated for quality purposes and not food-safety reasons. Does that still fall under the regulation, or is the regulation just specifically for food-safety purposes?
Need Help Ensuring FSMA Compliance?
The TAG team can help you identify gaps and update your food safety and recall plans. For more information visit www.achesongroup.com.
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Our FSMA Fridays Session: May 19
Save the date for our next session at 9:00 a.m. Friday, May 19, when we will explore The Foreign Supplier Verification Rule. Register for our monthly series at https://safetychain.com/resources/fsma-fridays/.
Check out the FSMA Fridays LinkedIn Group
Our LinkedIn group has grown steadily over the months to include over 100 members. Group participate offers opportunities for peer discussion, access to additional FSMA Fridays session content, and engagement in valuable dialogues around the management of FSMA compliance. Join today!
