Is Your Supply Chain FSMA Compliant?

The Food Safety Modernization Act (FSMA), a ruling built off of the 2005 Sanitary Food Transportation Act, went into effect on April 6, 2017. The act shifts the focus from responding to food contamination to preventing it by prohibiting the distribution of “adulterated food” or food that has been held under unsanitary conditions. FSMA affects all parties within the supply chain. This includes shippers/brokers, receivers, loaders, and carriers.

The act specifically addresses safety, not spoilage or quality issues for all human foods, animal foods, additives, and dietary supplements. It requires all parties within the supply chain to be aware of things like material failure of temperature controls, or other conditions which could cause the food to become unsafe – thus requiring all parties within the supply chain to work together and communicate more than ever before. Below are a few ways to ensure your supply chain is compliant.

Online training. Communicate the availability of the FDAs online training to your carrier base.

Communication with shippers. Shippers should provide the carriers and receivers with key information for transport such as temperature requirements, product descriptions, and special trailer cleaning requirements to ensure food product is safely transported.

Standardized communications.  Carriers should receive all of the shipper’s product specifications on their carrier tender to avoid miscommunications.

Updated contracts. Your company’s contracts with its carriers should include language on FSMA, as well as the cleanliness and condition of the trailers and seals.

Detailed records. Shipper orders, carrier tenders, and any other load specific information should be stored by all parties indefinitely for future reference.

Food safety requirements are changing, and it’s important to make sure not only your company, but also your logistics partners are compliant to ensure a safe and efficient supply chain. 

Time is Now to Check FSMA Readiness

We know the Food Safety Modernization Act (FSMA) will produce a significant impact within not only the food processing industry, but also all who provide services to processors. While FSMA will change how many do business, there are questions left unanswered.

Knowing non-compliance is not an option, perhaps it’s time to turn a few of those questions into action. Companies that store product or ingredients off-site with third-party warehouses can gauge the safety of their product by posing a few simple questions to their warehouse provider.

Ask to see their Hazard Analysis & Critical Control Points (HACCP) plan. The cornerstone of FSMA is identification of possible hazards to the safety of food products, and creation of controls/procedures to significantly minimize or prevent their occurrence. For facilities storing food products, a robust, written HACCP plan is a must-have for every product type. Absent this document, the facility will be at a severe disadvantage in terms of meeting FSMA standards for protecting your product.

What is their recall/traceability plan? Another of FSMA’s cornerstones is the ability to track and trace food products to prevent a widespread outbreak. Does the warehouse facility have a detailed plan? How often do they perform recall/traceability drills? If recalls and traceability exercises utilize paper instead of computers, it’s probably a red flag of their readiness for FSMA.

How is the facility audited? There are a variety of auditors and levels that facilities can be reviewed at – warehouse, food processor, etc. If the facility is not going through an audit process, it may be another FSMA readiness red flag. Regular audits are a key component of FSMA.

Gone are the days of selecting warehousing based solely on lowest price. With the introduction of FSMA, and its increased level of accountability, food processors must now choose a “partner” rather than a “service provider.” A partner will ensure the quality of the product as if it was their own, as well as comply with FSMA standards.

What is the Value of a HACCP Certified 3PL?

The Food Safety Modernization Act (FSMA) is changing how the supply chain functions. Moving forward, companies will need to be more aware of the safety and integrity of their products after they leave the production facility. Partnering with a 3PL company that is trained in Hazard Analysis & Critical Control Points (HACCP), and has a documented HACCP plan is the answer to FSMA standards.

HACCP is a systematic approach to the identification, evaluation, and control of food safety hazards. A plan must be crafted for each food-grade commodity the 3PL handles to ensure specific procedures are being followed. When choosing a 3PL, ask to see their HACCP plan for your commodity. Superior facilities will be able to produce this plan and walk you through their SOPs.

To acquire HACCP certification, facilities must complete a three-day course administered by companies such as ASI Food Safety Consultants. Sessions cover everything from why a HACCP plan is required, to building your own plan. Though retraining is not required, the best 3PLs will take this course every few years to ensure they remain best in class. 

Benefits of working with this type of 3PL include:

• Product safety. Companies gain peace of mind knowing their product's integrity is being protected while outside of their control. Product safety throughout the supply chain is critical. 

• Cost savings. HACCP certified 3PLs have such robust inspection processes that damage or pest issues are identified quickly at the time of receipt. This enables companies to quickly track the issue back to the carrier or porduction facility, making it easier to recoup incurred expenses while preventing future damaged product. 

• Avoid cross-contamination. HACCP certified 3PLs have thorough inspection processes, which help staff identify and deny entry of any contaminated (pest or other contamination) product. This eliminates the risk of cross-contamination with already stored food grade products. 

How Will FSMA Impact Carriers and Food Transportation?

While the Food Safety Modernization Act (FSMA) continues to be a work in progress, one thing is for certain – it will generate greater accountability. That accountability will extend through the supply chain to include carriers transporting food products for humans and animals.

The Food and Drug Administration’s (FDA) goal is to develop standards to ensure the safety and integrity of food products. Building off the Sanitary Food Transportation Act, FSMA will test carriers’ documentation skills. In addition, the new rules will bring equal accountability to shippers, carriers, and receivers of food products.

Setting standard operating procedures for tasks such as cleaning trailers, locking and sealing loads, and properly refrigerating products isn't particularly challenging. However, developing a process of collecting, organizing, and storing this information for easy retrieval at a later date is where carriers may face an obstacle.

New standards will make technology almost a prerequisite for carriers.

For instance, document management systems likely will be the norm for linking inspection paperwork to bills of lading. Likewise, the industry could see GPS systems in trucks become standard for carriers, as regulations demand tighter tracking and traceability of food products while they are on the road.

As FSMA approaches, it’s important that food manufacturers review the standard operating procedures of their logistics providers. Questions to ask are:

• Do they have established criteria for inspecting trailers before loading?
• How are these records maintained?
• How quickly can they be produced for review?
• Do they have standards for inspecting products upon arrival?
• How do they ensure trailers maintain the proper temperature for products?
• Do they have real time/GPS tracking and tracing capabilities with their equipment?