Now in the Same Corner—Mutual Compliance
A primary contributing factor to this lack of clarity seems to be that in its effort to ensure food is
safe and secure throughout the supply chain, FDA has created a critical relationship between two industry groups that, while historically coexisting in typical business arm’s-length professional transactions, must now work much more closely together toward mutual FSMA compliance.
One group regulated under the STR consists of food industry members that grow, store, load, process, ship, and/or receive foods that are dry, fresh, and/or require temperature control for food safety.
The other group that is now responsible for compliance under the rule is the trucking companies that
actually transport the food. These are typically owner-operators, which range from those having a fleet
size of fewer than five tractors and trailers to large carriers with fleet sizes in the thousands using employee drivers.
Previously, food companies needed their products transported, and they did not get involved in the actual
process of transportation other than to select a carrier and make sure that pertinent pick-up and delivery
information was properly dispatched. FSMA compliance now essentially requires food companies to become liable partners with their carriers.
Members of the food industry know that their products need to move, but the details and nuances of how
that transportation happens are typically managed by one group in their company: the logistics department.
Today, over a year since the rule became enforceable, there are employees in these logistics roles who have