Best Practices In The Safe Transportation Of Foods: The Sanitary Transportation Rule

Safe and sanitary transport of food is one of the cornerstones of any food supply chain and of food safety. It sometimes 

In the USA it is now enshrined in law under the The Sanitary Transportation of Human and Animal Food Rule (ST Rule). This became effective for big companies in 2016 followed a year later by the smaller firms. It is a cornerstone policy of the seven foundational rules under the Food Safety Modernization Act (FSMA).

Why do we need such a rule? Well, it is intended to ensure food we transport by whatever means does not become unsafe during travel in the USA. The actors or parties involved in this process happens to be anybody who handles food which is taken by car, train or plane to a destination. It means all those involved in transportation at the national level includes the shipper, loaders, carriers and receivers.

To show compliance with the ST rule, procedures must be in place that are acted upon to prevent contamination of any food or for any temperature abuse during transport. Those expectations must also be communicated  to other parties in the supply chain.

The ST rule relies on best practice on the following subjects:-

• temperature control,
• vehicle cleaning and maintenance,
• storage,
• loading practices,
• the exchange of information among various entities 

The Implementation is governed by the FDA and builds on a raft of safe best practices in this area of supply. It is also linked to reducing adulteration as with foreign bodies such as allergens or toxins.

The rule is to be found in 21 CFR Part 1, Subpart O which covers general provisions, equipment for transport, various transportation operations, the type of training required, what record retention and other requirements in records means when applied to shippers, receivers etc. and then waivers.

Bulk Commodities

Bulk commodities such as grain and feed have to be treated differently from small packaged food items and the chill chain foods.  It also has different considerations for animal foods. In this context of the essay we will refer to animal feed and specific nutritional foods for animals [other than man]. This includes pet foods, ingredients and intermediate animal food products.

The transportation of these foods must be accounted for by specific considerations within the ST rule. The implementation can never be  ‘one size fits all’. This implies that the type of food must be at the heart of any development of a process/protocol for safe transportation and bulk handling.

Ensuring Food Safety During Transport

When it comes to food safety, there are two aspects to be covered off. Preventing unsafe cross-contamination and cross-contact. Cross-contamination means clean products becoming contaminated with non-food products such as toxins, by people, by cleaning products etc.

Cross-contact refers to the situation when a residue of an allergenic food is unintentionally incorporated because of other forms of transport.

Determining An Effective Measure To Ensure Safety

Consideration is given initially to the type of food to be shipped. In most cases the onus is on the shipper of that food to make sure the ST rule is complied with. This follows a typical HACCP style guideline where the risks associated with hazards are considered.

Three types of food are important when thinking about implementing best practice. They are:-

1. raw materials or ingredients for human food processing in which allergens are a concern.
2. animal food where the pathogens are not a significant concern. Examples here are livestock and poultry feeds and ingredients for making these feeds such as  soya. In all situations allergens are not a concern with foods for animals.
3. animal food in which pathogens are of concern. An example would be animal foods stored in a home such as pet food. Young children or immunocompromised people can become ill if a pathogen is present if they inadvertently consume such a food.

The shipper must have effective measures in place. One of the most critical features is to communicate to other players involved in transportation. It is from the outset good practice to communicate in writing rather than verbally.

The Treatment Of Vehicles and Transportation Equipment

The vehicles used and the type of equipment used are important and there is an obligation to prevent contamination of them. It is beholden on the shipper to communicate specifications for safety. The three considerations are:-

• The equipment must be designed in a way which makes transport of food straightforward and should be of a quality and workmanship so as to be suitable for its intended use and that also includes cleaning. 
• It must be clear that transport equipment is maintained in an appropriate sanitary condition.
• Stored in a manner to prevent harboring pests or becoming contaminated.

Design Of Vehicles And Transportation Equipment

As with sanitary factory design, specifications for transporting bulk food are important.

• Walls, ceilings and floors of vehicles and transportation equipment are free of any sharp projections such as nails, staples, wire cables and so on that could produce contamination of food.
• Interiors of conveyances used to transport bulk food must minimise accumulation of food and facilitate adequate discharge and clean out.
• A water-tight transportation environment is needed
• Doors, hatches and tarps are tight fitting and provided with gaskets where necessary 
• As appropriate, the apparatus for doors, hatches and traps that facilitate the use of seals to ensure the integrity of the food.

Best Practice In Storage of Equipment 

Vehicles and other transportation equipment must be stored in an appropriate manner and condition. The factors to consider are:

• Length of time since last cargo. The longer an empty conveyance remains so, the greater the potential for contamination.
• The need for seals to ensure the integrity of the vehicle and transportation equipment. 
• Use of fumigants, which should only be used on food at the receiver’s discretion and in accordance with the requirements of the pesticide label.

Bulk Food Shipments

The Rules that Apply To Shippers

There are specific requirements in the FDA specifications apply to bulk foods. address potential for contamination by a previous shipment of food.

A shipper of bulk transported food must develop and implement written procedures adequate to ensure that a previous cargo does not make the food unsafe. The loader must have written agreement from the shipper to ensure food not unsafe.

Measures used to ensure food safety may be accomplished by the shipper or by the carrier or another party covered by the rule under a written agreement.

The Best Manufacturing Practices (BMPs) For Ensuring A Previous Cargo Does Not Make Food Unsafe

Consider an animal food in which pathogens are not of concern. The prior cargo information must be clear – in other words it must be clear to the shipper what the previous cargo was and conform a with a list of products deemed to be acceptable.

There must be information on a prior-clean out, (by the way this is critical for the next two BMPs as well). This should be available for review and conform with appropriate cleaning methods. Adequate clean-out may be accomplished by:

• dry cleaning through vacuuming, sweeping and/or blowing out with compressed air; or
• when dedicated vehicles or transportation equipment are used, adequate clean-out is accomplished by organoleptic inspection such as sight and smell, and periodic dry cleaning as necessary; or
• following International Database Transport (for) Feed guidelines.
• Objectionable food is key here so cleaning is important.

Adequacy of the cleaning process may be verified by organoleptic inspection after reviewing clean-out information.

The Best Manufacturing Practices (BMPs) With Animal Food When Pathogens Are A Concern

As before, the previous cargo which was carried must be identified and conform with a list of products deemed to be acceptable. The prior-clean information should be available for review and conform with appropriate cleaning methods. Adequate cleaning may be accomplished by using one or more of the following methods as necessary;

• dry cleaning
• washing with water
• washing with water and a cleaning agent
• disinfection; or
• following International database Transport (for) feed guidelines

Adequacy of cleaning may be verified by organoleptic inspection, and food contact pathogen testing.

BMPs:  Type of Food: Commodities For Human Food Processing In Which Allergens Are Of Concern

Where allergens are concerned, the previous three cargoes carried are identified and conform with a list of products deemed to be acceptable. This is intended to reduce the risk of allergen conveyance. 

The prior clean-out information should be available for review and conform with appropriate cleaning methods. It will mean contact surface testing just to ensure there has been appropriate high levels of cleaning especially where allergens are concerned.

Adequate cleaning in this case is also accomplished by:

• dry cleaning; and/or
• washing with water and cleansing agent; or
• when dedicated vehicles or transportation equipment are used, adequate clean-out may be accomplished by organoleptic inspection using sight and smell, and periodic dry cleaning and/or washing and cleansing agent, as necessary.

Cleaning may be verified too by organoleptic inspection, or food contact allergen testing.

What Should Written Procedures Contain

Written procedures must be clear but it also invites discussion on what the terms mean. You have to define terms such as the meaning of ‘clean’, wash-out, cleaning/cleansing agent, disinfectant and so on.

Documents and records must be written in such a way that it is clear to all that transportation has been performed properly. These procedures have to cover off responsibilities on which actions must be performed. The written procedures also need to cover off non-compliant situations and what the remedies happen to be.

What Are The Best Practices For Loaders As Opposed to Shippers?

A check-list based on specification provided by shippers. FDA does not require this evaluation.

Loaders determine the vehicle or transportation equipment is in an appropriate sanitary condition for the transport of the food before loading bulk food on to the conveyance

Communicate as necessary with the shipper and/or relevant parties and determine the appropriate disposition of vehicles and transportation equipment in non-compliant condition.

There Are Best Practices For Receivers Too

The receivers must establish specifications and conditions for vehicles and transportation equipment for which they require to be present for acceptance of food upon arrival. Such specifications and conditions should be communicated through written agreements with the shipper and/or other relevant parties.

Receivers must develop and implement appropriate written procedures to evaluate vehicles and transportation equipment to determine whether contamination of the food occurred during transportation.

The FDA does not require the receiver does not require them to keep a record on bulk transportation but it is good practice. The facilities must examine inbound materials suitable for use and transported in a manner that protects the food.

BMPs for Carriers

Carriers must communicate with shippers to ensure that vehicles and transportation equipment is suitably designed and adequately cleanable for their intended use for transportation operations.

Implement written producers to maintain vehicles and transportation equipment for their intended use to prevent food becoming unsafe during transportation operations.

What Level Of Training Is needed?

Training is probably one of the most critical features for implementation. Carriers must provide adequate training. The FDA has a one hour training video for all those keen to receive quality instruction with a certificate that can be printed off. The training requirement is only required for carriers but it would be good for all people involved. It means specific training requirements in manufacturing processing are needed.

All individuals involved in the transportation of foodstuffs need to have undergone some form of training associated with the various tasks needed to ensure sanitary haulage. Training must be completed prior to an individual performing a job. Not during or afterwards. It must be clear that responsibilities and duties are the key aspects. It must be delivered by a trained and qualified individual. Training has to be reinforced through periodic refresher sessions.

The Exemptions From The Sanitary Transportation Rule

Just to be clear about the scope of the Sanitary Transportation Rule (ST) rule. The exemptions from it relate to activities associated with food that is completely enclosed in a container. This means a sealed box, bag or bottle. It does not however exempt food that requires temperature control for ensuring food safety as this is contained within the ST Rule.

The other main exemption covers off activities associated with the transportation of human food co-products which are transported for use as animal food and do not need any further processing. The latter point is a very important consideration. If there is further processing needed then it would imply implementation of the law.

In the end, transportation of bulk human and animal food is best achieved safely if the best practices outlined already are employed.