Food Safety Modernization Act (FSMA) – Sanitary Transportation
In-Transit Temperature Monitoring
The Food and Drug Administration has just released final rules for “sanitary transportation” of food products that will be used for human and animal food. Feedback from the industry has prompted some changes from the initial draft language, and the FDA has published the final rules here.
This paper highlights passages from the FSMA text which shippers, carriers, and receivers will need to study as they formulate their SOPs, specifically with regard to in-transit temperature monitoring procedures when transporting perishable food products. It then recommends which actions shippers, carriers, and receivers should take to meet the outlined requirements.
Important excerpts of the rules:(bold, italicizedtext is directly from FDA)
- Primary responsibility for determining appropriate transportation operations now rests with the shipper, who may rely on contractual agreements to assign some of these responsibilities to other parties.
- Shippers must develop and implement written procedures to ensure that equipment and vehicles are in appropriate sanitary condition.
- Shippers of food transported in bulk must develop and implement written procedures to ensure that a previous cargo does not make food unsafe.
- And shippers of food that require temperature control for safety must also develop and implement written procedures to ensure that food is transported under adequate temperature control.
- If a covered person or company at any point in the transportation chain becomes aware of a possible failure of temperature control or any other condition that may render a food unsafe, that food must not be sold or distributed until a determination of safety is made.
- …..The shipper and carrier can agree to a temperature monitoring mechanism for foods that require temperature control for safety.
- The original proposal specified that a compartment must be equipped with a thermometer, temperature measuring device, or temperature recording device.
- The agency agreed with commenters that there are a number of effective ways for ensuring temperature control that parties subject to this rule should be able to use.
- The agency also agreed with commenters that carriers need to demonstrate they maintained requested temperature conditions only upon request, rather than as a requirement for every shipment, as previously proposed.
- The shipper (or shipper’s representative) now assumes formal responsibility to ensure the conveyance (trailer, truck, container, etc.) meets the suitability requirements for the sanitary transportation of food products as defined by the act.
- These guidelines also expressly promote necessary cooperation between the shipper, carrier, and receiver (customer) to ensure and confirm effective temperature control throughout the loading, transportation, and receiving/acceptance of subject perishable food products.
- Expensive “real-time” temperature monitoring technology is NOT required.
- Electronic temperature monitoring and/or recording devices are acceptable.
- Carriers must provide, upon request, proof that requested temperature conditions were maintained during transportation.
How Can shippers, carriers, and receivers comply with the new FSMA Sanitary Transportation Rules with respect to in-transit temperature monitoring?
Cargo Data Corporation recommends shippers, carriers, and receivers each study the FSMA text to determine their responsibilities. Clearly, accurate temperature records, ease of use, cost effectiveness, transparency, and easy data archiving features will be important aspects of any in-transit temperature monitoring program.
Cargo Data’s Lightning NFC temperature monitoring system is designed specifically to be a turn-key system that meets the needs of most shippers, carriers, and receivers to achieve FSMA compliance for in-transit temperature monitoring. Visit the website (LightningNFC.com) to view a brief video presentation highlighting Lightning NFC operations, features, and benefits.
For the Shipper: Lightning NFC instruments are easy to activate and place. The shipping clerk simply notes (or scans) the instrument serial number for inclusion in shipping documents, order passing, and BOL. Cargo Data also recommends the shipping clerk write the shipment’s PO number and other shipping details on the instrument label as a backup, in case the instrument becomes separated from its intended shipment.
For the Carrier: No action is required by the carrier beyond confirmation that the Lightning NFC instrument has been placed in the shipment and the instrument’s serial number is listed on the shipment BOL/Manifest.
For the Receiver:Lightning NFC temperature monitoring instruments are provided in a high-visibility moisture resistant pouch which make it easier to locate the instrument within the shipment. Lightning NFC is also available with a free optional locating beeper which sounds intermittently to provide location assistance (not recommended for export shipments).
Lightning NFC instruments use NFC wireless technology to transfer all temperature data to a smartphone or tablet. The receiver/inspector can instantly view the temperature data, make arrival quality notes, document internal (pulp) temperature, and even add photographs of the shipment to the temperature record. All temperature data, notes, and photos are automatically sent to Cargo Data’s UpLink cloud server for permanent archiving.
UpLink Online Temperature Data Review: Shippers, carriers, and receivers can view the shipment’s temperature data online as soon as the receiver transfers data from the instrument to the smartphone or tablet. Simply navigate to LightningNFC.com or cargodatacorp.com and enter the instrument serial number into the UpLink data retrieval field on the homepage. A free and fully detailed temperature report is available for viewing, printing, and/or downloading.