"Any company engaged in the transportation of food should develop standardized policies, procedures and training to ensure food safety and compliance," advised Oldham. "The act expands on risk-based controls to decrease the likelihood of food becoming unsafe while in transit."
Most companies must be in compliance by April 2017, but there are a few exceptions. Small businesses other than motor carriers who are not also shippers or receivers with less than 500 employees have until April 2018 to comply. Motor carriers that have less than $27.5 M in annual receipts also have until April 2018 to comply.
To help companies comply, Oldham outline five key areas of the FSMA rules.
- Requirements –What shippers, receivers, loaders and carriers need to know for effective food controls.
- Responsibilities – The specific responsibilities of shippers, receivers, loaders and carriers for compliance.
- Training – Carriers are required under a food contract for food safety in transit to train engaged personnel.
- Records – Carriers, shippers, loaders and receivers must maintain records of any written agreements associated with FSMA requirements for 12 months beyond termination of those agreements.
- Waivers – The FDA can wave requirements under FSMA if it is determined through a petition that the waiver will not result in in unsafe food transportation.
"These new requirements expand regulation beyond the US Department of Agriculture's (USDA) Hazard Analysis and Critical Control Point program and expands on risk-based controls," said Oldham.
These rules apply to food transportation beyond those transshipped through the United States, imported from future exports or regulated by the USDA for inspection of meat, poultry and egg products. Read Oldham's white paper "Good Enough to Eat," for more information on implementing FSMA.
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