Ensuring Safety and Regulatory Compliance During Food Transportation

Logistics and transport considerations aren’t just a major factor in the global food supply chain — they also play a significant role in domestic interstate food transportation. Given the vast size of the continental United States and the varying climates across the country, ground distribution can be just as complex and challenging as international transportation.

In 2018, the FDA published FSMA Final Rule on Sanitary Transportation of Human and Animal Food, establishing specific requirements for shippers, carriers, loaders, and receivers of food products. The rule mandates practices related to temperature control, cleanliness, training, record-keeping, and risk mitigation to prevent food contamination and ensure safe food transportation across the food supply chain. Here are the responsibilities of each stakeholder involved in transport: 

1. Shippers 

The FDA classifies shippers as any person or entity that sends food through or into the United States with ground transportation (automotive or rail). If food products enter the U.S. by sea or air, the person or entity that arranges the transfer of containers through ground transport channels is also classified as a shipper. 

The FDA encourages shippers to properly vet carriers, ensure they are aware of FSMA rules, and transport food in a safe, sanitary, and compliant manner. This protects downstream stakeholders from food safety issues that can result from unsafe transport, including poor temperature control or improperly sanitized equipment. Shippers are primarily responsible for verifying the carriers they hire are compliant with these FSMA training and documentation requirements. They also need to draft and maintain detailed written procedures and agreements with carriers and receivers for up to 12 months after transport. 

Generally, shippers are not responsible for the actual sanitary conditions or temperature controls in transport vehicles. However, rail operators often do not own, prepare, or operate refrigeration units and other equipment in their railcars. In cases where the shipper actually owns refrigeration units and other equipment, the FDA has agreed that shippers are responsible for compliance, including inspection and maintenance. 

2. Carriers 

The FDA classifies the people and organizations directly responsible for food transportation as carriers. Because of their critical role in transporting food, they face the most stringent demands from the FDA for compliance with FSMA, and are most often subjected to inspection. Carriers must: 

• Train personnel (and maintain training documentation) on sanitary transportation practices and maintaining sanitary conditions for vehicles throughout each trip (except in cases where the shipper is responsible for equipment sanitation, such as in railcars). 
• Install, operate, and maintain temperature monitoring mechanisms in each transport vehicle in accordance with shipper agreements. 
• Take necessary steps to prevent cross-contact between food items — especially to prevent introduction of allergens.  

3. Loaders 

Loaders are classified as any person who physically loads food onto a motor or rail vehicle. Accordingly, loaders encompass employees of both shippers and carriers, depending on the specifics of a shipment. 

Loaders are directly responsible for: 

• Ensuring food transportation equipment is in appropriate sanitary condition prior to a shipment 
• Maintaining temperature control, including verifying that each cold storage compartment is fully functioning and prepared for refrigerated transport such as precooling when necessary 

4. Receivers

Receivers are classified as any stakeholder that accepts food products from shippers and carriers. Receivers exist within every part of the supply chain, and can include manufacturers, distributors, retailers, and restaurants. 

Upon accepting a shipment, receivers should review the temperature history of the vehicle to verify food was transported in proper temperature ranges throughout the entire journey, and inspect the sanitary conditions of the vehicle and equipment to ensure the carrier was in compliance with regulations. This due diligence can prevent a receiver from allowing spoiled products, pathogens, or other contaminants into their facility, and make it easier to trace the source of contamination if an outbreak occurs later. 

Meet Food Transport Compliance With AIB International 

Upholding food safety and regulatory compliance during food transportation takes careful planning, abundant resourcing, and expert employee training. Trustworthy and experienced third-party support is critical to making sure your organization follows FSMA guidelines correctly, no matter where you fall in the supply chain. That’s where food safety consultants come in. AIB International offers a number of training and certification programs to help stakeholders with all aspects of food transportation, including IFS Logistics and BRCGS Storage and Distribution Standards.