Does the Sanitary Transport Rule apply to you and if so are you a carrier or are you working with carriers? Remember, the first compliance date for businesses covered by the Sanitary Transportation Rule was April 6, 2017. The compliance date for small businesses is April 6, 2018. If you are a carrier of food within the U.S., it just got a little easier for you to meet the training requirements of FSMA’s Sanitary Transportation of Human and Animal Food Rule (Sanitary Transportation Rule). On September 20, FDA published a free, one-hour online food safety training module for carriers engaged in the transportation of food by rail or motor vehicle in the United States. The Sanitary Transportation Rule requires covered rail and motor vehicle carriers to provide food safety training for their personnel engaged in transportation operations. That training can be conducted through the use of the FDA module and/or a company’s own training program or third-party training that satisfies the requirements of the rule. Additionally, records documenting the training of operations personnel must be maintained and provided to FDA upon request. Although the rule places much of the responsibility for establishing safe food transportation procedures on the shipper, the carrier training requirement applies when the shipper and carrier have agreed, in a written contract, that the carrier is responsible, in whole or part, for sanitary conditions during transportation operations. The FDA module satisfies this requirement, and also can be used to complement other training. The Course Designed to provide basic food safety training to transportation operations personnel and complement industry best practices, the objectives of the course are to help carrier personnel recognize their responsibilities under the rule, identify potential food safety problems that may occur during food transportation, and describe common ways to prevent food safety problems. The online module operates just like a PowerPoint, with the user clicking Next as a screen is completed (or Prev. if he or she wishes to look back at a previous slide). Although the first screen that comes up is a pop-up window requesting log-in credentials, closing out of the window takes the user to the module or downloads the LMS package, depending on which link was clicked. As FDA explains in the module’s introduction, the rule requires carrier firms to provide basic food safety training to personnel engaged in food transportation operations. The training module does not describe specific operation procedures and practices, rather it is intended to compliment the carrier’s existing training, while fulfilling the requirements of the rule. Additionally, the course does not provide a complete overview of the Sanitary Transportation rule, but is intended to train carriers in their responsibilities. The course focuses on four critical elements of the rule: vehicles and transportation equipment, transportation operations, training, and records. Each element then focuses on food safety risk to ensure that transportation practices do not cause food to become unsafe during transport. Throughout the course, FDA includes “Knowledge Checks” quizzing the user on what was just learned. For example, Knowledge Check 1 asks: “Under the Sanitary Transportation Rule, the term ‘——–’ means a person who physically moves food by rail or motor vehicle in commerce with in the United States.” The participant selects the correct response from four options. A correct response brings up a pop-up box stating the answer is correct, commending the user, and explaining the answer. An incorrect response pop-up asks the user to review the information and try again. When an individual successfully completes the online module, a certificate of completion can be printed with the user’s name, which can be used as documentation of completion. Course files also can be downloaded into a company’s own Learning Management System (LMS) to enable automatic tracking of personnel’s completion of the course. The Sanitary Transportation Rule applies to businesses that act as shippers, receivers, loaders or carriers of human or animal food in the U.S. by motor or rail vehicle – whether or not the food is offered for sale or enters into interstate commerce. It also applies to persons who ship food to the U.S. by rail, ship, or air and arranges for the transfer of the intact container onto a motor or rail vehicle for transportation in the U.S. if the food will be consumed or distributed in the U.S. In summary, this is a great tool that will help carriers subject to the Sanitary Transport Rule to check the training box. It takes all the guess work out of what FDA will require and what is considered adequate training. It also builds in the recordkeeping component which, as we all know, FDA is very focused on. As a reminder, the first compliance date for businesses covered by the Sanitary Transportation Rule was April 6, 2017. The compliance date for small businesses is April 6, 2018. About The Acheson Group (TAG) Led by Former FDA Associate Commissioner for Foods Dr. David Acheson, TAG is a food safety consulting group that provides guidance and expertise worldwide for companies throughout the food supply chain. With in-depth industry knowledge combined with real-world experience, TAG’s team of food safety experts help companies more effectively mitigate risk, improve operational efficiencies, and ensure regulatory and standards compliance. Learn more at: www.AchesonGroup.com
