Food Safety / HACCP Plan - Transportation
Plan Guidance Introduction
Transportation of food products currently fall under the regulatory rules of the United States Food and Drug Administration’s Food Safety Modernization Act Preventive Controls for Human Food. On April 6, 2016, FDA published in the Federal Register a final rule, Sanitary Transportation of Human and Animal Food (Sanitary Transportation rule) (81 FR 20091), that establishes requirements for shippers, loaders, carriers by motor vehicle and rail vehicle, and receivers engaged in the transportation of food, including food for animals, to use sanitary transportation practices to ensure the safety of the food they transport. The final rule became effective on June 6, 2016. This plan guidance page will walk through the basics of developing a food safety plan for transportation of regulated food products.
Types of companies that would use this plan would be:
- Food Transportation Companies
- Food Transportation Companies with a Warehouse
Types of products that would use a version of this guidance would be:
- Carrier Services
- Sanitary LTL with Warehouse
Food Safety / HACCP Plan
The Food Safety Plan (HACCP or Preventive Controls) is not a stand alone program, but rather part of a larger food safety system. The foundational programs that are part of the food safety system are frequently termed prerequisite programs. The term was coined to indicate that they should be in place before HACCP based systems are implemented in order to effectively manage risk from foodborne hazards. The Current Good Manufacturing Practice (GMP) regulations address requirements for many prerequisite programs. The regulation (117 Subpart B) that outlines the conditions and practices the regulated food industry must follow for processing safe food under sanitary conditions, including personnel, plant and grounds, sanitary operations, sanitary facilities and controls, equipment and utensils, processes and controls, warehousing and distribution, and defect action levels considerations. Elements of GMPs that are not covered in the Food Safety Plan are still required by regulations.
If your operations holds, stores, handles LTL or partial truckloads, or maintains a facility for either interstate or international transfers, consider reviewing your GMPs to comply with your contractual agreements and new FSMA requirements for preventative controls.
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Process Flow
The process flow of a food safety plan (HACCP or Preventive Controls) is the center of a food product’s food safety story. It tells how a company makes it’s products and also what hazards and controls are associated with each step. Here’s an example process flow for transportation:
Potential Hazards
Transportation companies have several biological, chemical, and physical hazards to control for proper food safety. Here are a few examples:
- A threat to Maintaining Cargo's Temperature
- Human Pathogens
- Foreign material contamination
- Allergen Cross Contamination
- Biological
- Physical elements can not penetrate sealed reefer doors
- Laboratory testing is suggested for transport hazards : Listeria and Bacteria - Staphylococcus aureus
Suggested Standard Operating Procedures (SOPs)
SOPs are related to both GMPs and Controls of Hazards in the Food Safety Plan. SOPs define the specific steps of how GMPs and Controls of Hazards mitigate food safety hazards and define a repeatable process.
- Operations (Trailer) – Set temperature and Record initial temperature previous SOP – Preventative Maintenance
- Vehicle & Transport Equipment Cleaning & Sanitizing
- Pre-Trip Inspection
- Using and Calibrating Thermometers
- Operations and Employee Food Safety Training
- Using and Calibrating Thermometers
- Operations and Employee Food Safety Training
- Cleaning and Sanitizing Food Contact Surfaces
- Storing and Using Poisonous or Toxic Chemicals
- Preventing Cross-Contamination During Storage and Preparation
- Receiving Deliveries
- Cleaning Building and Facility
- Allergen Control Program
- Washing Hands – To prevent foodborne illness by contaminated hands
- Employee Illness Program
- Using Suitable Utensils When Handling Ready-to-Eat Foods
Suggested Logs and Records
Monitoring records and logs must include the actual values or observation that document the actual implementation of a Food Safety Plan . For example, if a temperature is being measured, the actual temperature must be recorded rather than a check mark indicating that the temperature complied with the critical limit. To comply with regulations, information must be recorded at the time it is observed.
Here are suggested record and log types to use:
- Shipping Temperature Log
- Receiving Checklist
- Customer Complaints
- Corrective Action Forms
- Employee Training
- Raw Materials Log
- Worker Illness Log
- Customer Complaints
- Corrective Action Forms
- Food Safety Quarterly Audit
- Food Safety Checklist
Suggested Supply Chain Documents
The safety of your product depends on much more than just what you control within your own facility. Use of an ingredient that has a history of association with a specific hazard may require a supply chain program as a control within your food safety program. Companies may have extensive supplier programs that encompass much more than food safety elements to manage their supplier expectations and performance.
Here is a list of suggested documents to obtain from your supply chain:
- Food Safety HACCP or Preventive Controls Plan for each product
- Food Defense/Business Continuity Plan
- Validation of each product and/or process and Ready-To-Eat statements (if applicable)
- Certificates of Analysis (COA)
- Third Party Audit Certificate, Report & Corrective Actions
- Product Specification
- 100g Nutritional Information
- Allergen Grid / Statement
- SDS / MSDS Statement
- GMO / Non-GMO Statement
- Country of Origin
- Kosher Certificate (Provide Yearly when due)
- Halal Certificate (If Applicable)
Additional Components for Compliance (Recommended)
The following associated food safety components are recommended to achieve compliance with State and Federal rules and regulations.
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Recall Plan
According to the Food Safety Modernization Act, Preventive Controls for Human Food regulation requires the development of a written Recall Plan when a hazard analysis identifies a hazard requiring a preventive control. Recalls are actions taken by an establishment to remove an adulterated, misbranded or violative product from the market. In other words, a product for which FDA or a state could take legal action against the company would be subject to recall.
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Verification
Verification is an important component of supply chain, sanitation, allergen and critical controls. It confirms that the Food Safety Plan is operating as intended. Validation confirms the effectiveness of the Food Safety Plan in controlling food safety hazards. The purpose of verification is to provide a level of confidence that the Food Safety Plan is:
1) based on solid scientific principles that are adequate to control the hazards associated with the product and process, and
2) that the plan is being followed correctly every day of operation.
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