of ensuring compliance throughout the company; creating an open and encouraging atmosphere will make employees more willing
to contribute in valuable areas.
Some families or friends have code words
to use when they are around each other in
a difficult or uncomfortable situation. For
example, a husband or wife may say “parsley”
in a conversation when they see their spouse
with something scary in their front teeth that
may be embarrassing if not removed.
Companies that buy and sell from each
other in some capacity need to be willing to
help their company’s partners avoid a problem. Ignoring something potentially risky is
not what good partners do. This starts with
communication but should move quickly
to collaboration so that both entities’ food
safety plans can withstand scrutiny.
Dispatchers and drivers are often put in
the hot seat when a problem arises at a customer’s or supplier’s dock. For example, a
driver may have been careful to get a trailer
cleaned and properly prepared, but once
backed in and ready to start loading, the driver notices mud, debris, or sometimes blood
on the forklift tires or on product boxes. Perhaps in a situation where a load that requires
temperature control for safety, the product
has not been properly cooled to the correct
If this happens once or twice, it is probably not a serious risk. However, continuous
disregard for a customer’s or supplier’s requests to use safe food transportation practices might indicate that it is time to make
a change. Of course, this is easier said than
done, but it is a better alternative than hop-ing that a lucrative relationship stays lucky
and does not lead to a fine, making someone
ill, or something even worse for the CEO.
And those drivers and dispatchers stuck
making the decisions about whether to load
or not load? Insisting that they look the other
way opens the door for other areas of non-
Look Inside and Out
In building a plan, a good starting point,
especially for food safety personnel, is implementing what these folks are already good
at, namely, using objective scientific testing
in trailers, typical functions like employing
audits and corrective actions, and for sure,
putting to use all the food safety vocabulary
words so that your transportation food safety
plans align with other areas of the company’s
food safety initiatives.
Carriers may need to work on understanding food safety language, but using that language and applying it to the procedures that
are working and align with the STR will help
the transportation company write a solid,
complete plan that will satisfy their customers’ food safety departments.
But perhaps just as useful for either a food
or transportation company is to look outside
their industry to learn how other transportation sectors accomplish compliance.
Examine maritime or aviation systems.
Each of them has a high level of risk management because of the dangerous results of
noncompliance (see “STR Flight Plan,” p.
In closing, and speaking of the field of
aviation, there is a retired colonel that told
his freshman class of aviation majors, “Taking
off is optional, landing is mandatory.” This is
a great summary of the responsibility the STR
has placed on the food and transportation
industry members. If a company is involved
in the movement of food, compliance is
Pam Young, of Pam Young & Company, is cofounder and
managing partner of Healthy Trailer LLC. She focuses on
driver awareness and skill acquisition to best align companies’ compliance plans under the Sanitary Transportation rule.
“Many of these are contracted carriers for some of the largest foodservice, retail, and
its FSMA compliance costs
than other factors such as the
types of food it produces.
We mentioned that companies cited allergen control
(number four for U.S./
Canada and number one for
international companies) as
one of their key compliance
issues. We anticipated this
response and, as part of this
survey, we also asked detailed
questions about how processors are changing their allergen control programs.
We first asked, “Has
FSMA changed the way that
you test or control for al-
lergens?” Roughly 30 percent
reported that FSMA had
caused them to implement
specific changes. We then
asked what these changes
were, and the most frequent
answer, with more than 40
percent of the responses, was
We will expand further
on this allergen program
data from the survey in our
next edition of Food Safety
Insights. We will report how
much additional testing is
being done and the analytical
methods being used. Allergen
control is, of course, more
than just testing, so we will
also describe the changes in
other program elements such
as segregation and labeling.
We asked what products or
services processors would find
most valuable to help them
improve their programs. We
look forward to bringing
those insights to you in the
next issue. n
Bob Ferguson is president of Strategic
Consulting Inc. and can be reached at
firstname.lastname@example.org or on
Twitter at @SCI_Ferguson.