In questions that are not “practice”
related and more specific to a definition
in the rule, such as whether a company
is in the shoes of a shipper, it is better
to assume that a company has a specific
role. Write a protocol for that role rather
than ignore the requirement. Definitely
have a company attorney review the
food safety plan.
Not only did FDA intend to incorporate flexibility into the STR, but it
also relied on industry “best practices”
to help provide the framework for transportation protocols and procedures.
The assumption was that these accepted
means of managing freight movement
are consistently incorporated and implemented by all parties specified in the
rule, whether or not the practices are
embodied in a written food safety plan.
This too was a good idea, except that
in food transportation, a multi-faceted
and historically ignored industry (in
relation to food safety rules), companies
have been moving food products in
patterns and with procedures that best
accommodate their operations and customer needs. Safe food transportation
may be a consideration but not always a
The STR is activity-based, so FDA
expects that stakeholders will know and
actually practice these guidelines. However, one of the criticisms of established
best practices that has surfaced since
the rule’s publication is that while they
make sense on paper, the outcomes fall
short when actually executed. This can
happen because there is insufficient scientific support for the quality of a practice or because of inadequate training of
the people responsible for understanding it.
Here is an example that demonstrates
In regard to science, the STR requires
transportation equipment to be “clean.”
This means that when, for instance, a
driver pulling a refrigerated trailer arrives
at a cooler, at a minimum, the trailer
should be free of debris and should not
have past cargo odors.
Unless the carrier is contracted to wash out the trailer after every load or every
type of cargo, “clean” refers to making sure that visibly there is no dirt, substance, or
product/pallet pieces remaining on the floor or stuck to the walls.
Any bacterial material, invisible to the naked eye, could still be in the trailer.
Washouts are not regulated, so some surfaces do not even get rinsed and at times can
be cross-contaminated because of the washout method used by a facility.
How does inadequate training affect the quality of a washout? Many companies
tell their drivers to get washouts, but they do not necessarily give them instructions on how a washout service provider should clean a trailer or how often a trailer
Learn more or try a pilot.
firstname.lastname@example.org — controlant.com
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