Time to invest in Your FSMA Compliance

The Roborock E25 Robotic vacuum cleaner.  Today’s Amazon Deal of the Day. There it was early this AM when I first checked my email.  I wish I hadn’t taken a quick peek at it’s features because now, of course, I want one.

One problem--the price. Thinking through all the things it could do for me, I can almost justify the spend.  We have two cats who do not brush themselves. It’s been raining a lot, so all the mud and dirt that gets tracked in would be automatically pick up.  Seventy-five percent of my kids are gone now, so when we have company, I have to do the vacuuming. Oh, I want this bad.

The description says it is not only effective, but also intelligent.  ‘Thirteen on-board sensors provide drop avoidance, anti-collision, trap prevention, self-charging and resumption.’  I don’t even know what some of these features mean! And no wonder it takes me so long to vacuum! My 5 year old upright doesn’t have any of this stuff.  I wonder how much the sensors cost to replace? What happens to ‘effective and intelligent’ when then sensors fail? Chase my cats?

But $299? Umm...I watched the little counter on the side of the offering tick down while I thought through the decision.  Finally, automatic, robotic, efficient and even smart can’t sway me to click this tempting buy into ‘Add to my Cart.’

You know, I would have totally been all over this purchase if the government made me do it.  It may legally require me to do a lot of things, but being on top of the vacuuming is not one of them.  Yet.

Spending money on things we think we may not need sometimes keeps us from making good decisions on things that matter.  

For example, now required by FSMA for all of us involved in transporting specific categories of food, maintaining trailers in a sanitary condition is not an option.  While the rule is not ‘prescriptive’ (FDA’s word) it does require ‘clean and sanitary.’

Similar to my vacuum decision, in the minds of many people who are transporting food, this governmental regulation is a choice.  In the absence of a shipper’s specification, a carrier has the discretion to determine the frequency or type of prior cargo that warrants some type of trailer sanitation for one of its trailers.  

It is true that this while ‘sanitary condition’ seems fairly straightforward to understand, it is anything but uncomplicated.  There are very few reported and proven instances of how an unsanitary trailer contributed to a foodborne illness outbreak and scientific data is minimal.  And to make things more murky, there are often as many opinions on how best to clean a trailer as there are experts.

So where does that leave us?  Should we buy a washout or not?  Sort of like the Deal of the Day, the clock is ticking and it is time to get procedures lined out for your food safety plans.  

This is true for at least three reasons:  

1) A driver who decides not to get a washout may be sent away at the cooling dock, creating serious time delays;

2) If you find yourself involved in an outbreak because of some part you played in the supply chain, you will want to prove that you understand the FSMA requirement, and have properly complied;

3)At some point in the future, there may be a customer or vendor that your company needs to help it grow or improve, and your ability to produce trailer sanitation records will demonstrate that you understand compliance with the rule.

Here are some quick suggestions on how you can show FSMA sanitary compliance:

• Check with your washout vendors about their cleaning procedures.  Do they use chemicals? Do they clean their hoses and equipment? Do they have any testing protocols to show you that they are giving you the clean that you are paying for?
• Establish company protocols about when you expect your drivers to get a trailer sanitation service so that they aren’t on the road guessing about what is proper procedure;
• Maintain records of washouts and keep them in your food safety plans;
• Check with your customers about their trailer sanitation requirements for your trailers;
• Make sure the people who are in your trailers loading or unloading your loads are following FSMA protocols.

When my kids grumble about helping me with the vacuuming,  I tell them, “You want cats? They are furry. Vacuuming (with my barely efficient and not smart vacuum) is non-negotiable.”   

So my advice to you is that if you have a role in the food transportation supply chain, the FDA expects you to comply with all parts of their rule, including trailer sanitation. It's non-negotiable.