This year, many companies in the transportation industry will be required to comply with the FSMA Sanitary Transportation rule. Though this rule has been in effect since April 2017, many carriers were given an extra year to implement the practices and processes necessary to become compliant. If you transport, receive, or otherwise participate in the process of transporting human and/or animal food, you may be among those subject to the FSMA Transportation rule.

If the FSMA Transportation Rule Affects You…

As a general rule, if you’re a carrier, shipper, receiver, or loader involved in the transportation of human and/or animal food in the United States, you are probably subject to the Sanitary Transportation rule. A number of exemptions to this rule have been established and may apply to your operation if it is involved in the transportation of:

• Food moved through the US to be transshipped to another country
• Imported food destined for export
• Food in facilities regulated exclusively by the Department of Agriculture
• Compressed food gases
• Food contact substances (as defined in Section 409(h) of the Federal Food, Drug, and Cosmetic Act)
• Food for farm activities
• Byproducts of human food that are intended (without further processing) for use as animal food
• Food that does not require temperature control and is enclosed completely within a container
• Live animals for food

Meeting the Deadline

The Food and Drug Administration has encouraged all operations subject to the FSMA Transportation rule to comply as soon as possible. The deadline for large, non-exempt businesses passed on April 6, 2017. Small businesses (defined as non-carrier businesses with less than 500 full-time employees or carriers who do not act as shippers or receivers and have less than $27.5 million in annual receipts) have until April 6, 2018 to comply.

Implementing Compliant Practices

While there are some specific requirements that may only apply to certain operations, every transportation operation that is subject to the FSMA rule is required to implement the following:

• Measures (in the form of isolation, protective packaging, etc.) to protect food from raw food and nonfood contamination during transport.
• Measures (in the form of isolation, segregation, hand sanitization, etc.) to keep food that is not enclosed in a container from being subject to cross-contact or becoming contaminated during transport.
• Measures to ensure that TCS foods (foods requiring temperature control for safety) are given adequate temperature control during transportation.

Staying Cool and Compliant

Whether you’re subject to the FSMA rule or not, the processes and requirements outlined therein define the practices which are being embraced by most within the food transportation industry. The Food Safety Modernization Act was created to set the standards for modern food production and handling processes, so it’s probably safe to assume that adopting these as soon as possible will save your business both time and hassle in the future.