Technology & Maintenance Council . . . Turning Experience Into Practice
Attention Please • In accordance with TMC Board Policy, all personal phones without a silent feature must be turned off during business sessions. • If you must use your phone —please leave the room!
Attention Please • This is an open meeting of the Technology & Maintenance Council, held in accordance with ATA Antitrust Guidelines which are listed in your meeting packet.
• Audio or video recordings are not permitted at this session. However, photography is permissible. • The opinions expressed in this meeting are those of the individual and not necessarily the opinion of his/her company nor of TMC unless stated otherwise.
Antitrust/Patent Disclosure • To minimize the possibility of antitrust problems, the guidelines detailed in your registration packet should be followed at all TMC meetings, task force and study group sessions. • All participants in any group involved in the development of standards or recommended practices shall disclose, as stated in the antitrust/patent disclosure guidelines in your registration packet, all patents or patent applications that are owned, controlled or licensed by the Participant or Participant’s employer when the Participant reasonably believes such patent or patent application may become material to the standard or RP development process.
Constructive Comments Are Always Appreciated! TMC welcomes your comments, but please make certain that they are constructive and appropriate before you turn in your evaluation sheet! Thank You for Your Cooperation!
2015 TMC Annual Meeting Your Trailer – Clean It! Warren Hoemann SVP Industry Affairs American Trucking Associations
FSMA Overview • Signed into Law January 2011 • Resulting from several food borne outbreaks – Spinach, peanuts, melons
• Main focus on handling, manufacturing, processing of food • Carrier specific: Section 111 – Sanitary Transportation of Human and Animal Food (STF)
STF
• Proposed rule on February 2014 – 120 day comment period + 60 day extension • FDA Goal “to ensure that transportation practices do not create food safety risks” • FDA believes that the current transportation methods used in the U.S. are working • ATA Goal – Continue to communicate our safety record to FDA, while minimizing any unnecessary additional regulatory burdens on the industry
ATA Concerns • ATA Concerns – Additional cost to the industry w/out quantifiable benefit – Increase in training and recordkeeping requirements – Mandatory Precooling – Questions remain on how it will be enforced and by whom
What you need to know • Communication is Imperative – Requirements are placed on the shipper and need to be followed by the carrier and receiver – FDA does not require temperature thresholds for products -- they require the carrier follow those thresholds put forth by the shipper, and require them to be available to the receiver
Need to know cont. • FDA does not provide guidelines or require cleaning your trailer a certain way -- they require following the shipper’s guidelines on how and when to clean the equipment, visually inspect it and document it. • Most important takeaway -- the STF requires everyone (shipper, carrier, receiver) be communicating and on the same page.
FSMA Timeline • • • •
ATA requested FDA reopen comment period Most rules schedule to be finalized in 2015 STF scheduled to be finalized March 2016 STF rule in effect 60 days after publication – 1 year compliance period for all companies not considered a small business – 2 year compliance for small businesses
Jon Samson American Trucking Associations Agricultural and Food Transporters Conference 950 N. Glebe Road, Suite 210 Arlington, VA 22203 (703) 838 - 7955 jsamson@trucking.org
Food Safety Modernization Act
2015 TMC Annual Meeting Your Trailer – Clean It! Bud Rodowick Strategic Relations – Food Safety & OEMs Thermo King
Food Safety Modernization Act As a refrigerated fleet, understanding how my customers will interpret these proposed rules of FSMA is important. • Hazard Analysis and Preventive Controls - FSMA Sec. 103
• Enhancing tracking and tracing of food and recordkeeping FSMA Sec. 204 • Sanitary Transportation of Food - FSMA Sec. 111
• Protection against intentional adulteration - FSMA Sec. 106 • Foreign Supplier Verification Program - FSMA Sec. 301
Food Safety Modernization Act The FDA will Publish These as Final Rules • Enhancing tracking and tracing of food and recordkeeping June 30, 2015 • Hazard Analysis and Preventive Controls August 30, 2015 • Foreign Supplier Verification Program October 31, 2015 • Sanitary Transportation of Food March 31, 2016 • Protection against intentional adulteration May 31, 2016
Food Safety Modernization Act
FSMA Compliance Starts With “The key... is that the new law explicitly places primary responsibility for food safety -- for prevention -- on food producers and processors,� Taylor said. (FDA Deputy Commissioner for Foods, Michael R. Taylor)
Food Safety Modernization Act Why do I have to have a clean trailer for FSMA compliance? •Compliance requirements identified from the Food Safety Modernization Act require a food producer or processor to perform Hazard Analysis (HACCP) and Hazard Analysis and Risk Based Preventative Controls (HARPC) to ensure that food is not adulterated. •From the moment food products are placed into the staging area on the shipping dock until they are unloaded at the receiving dock and stored; that entire process and all aspects of it now should have Hazard Analysis, Preventive Controls, Sanitation, Monitoring, Verification, Recordkeeping, and Corrective Actions written into a Food Safety Plan to be in compliance. •Don’t be held hostage be part of the solution.
Sanitary Transportation of Food Sanitary Transportation of Food Proposed Rule Compliance Requirements
“The proposed rule would require that shippers specify to carriers in writing the sanitary requirements for a vehicle or transportation equipment to be provided for all food subject to this proposal and the temperature requirements for foods subject to temperature control requirements. “
Sanitary Transportation of Food Sanitary Transportation of Food Proposed Rule Compliance Requirements “Proposed § 1.904 would define "transportation equipment" to mean equipment used in transportation operations, other than vehicles, e.g., bulk and non-bulk containers, bins, totes, pallets, pumps, fittings, hoses, gaskets, and loading and unloading systems and also state that transportation equipment would also include a railcar not attached to a locomotive or a trailer not attached to a tractor.”
Sanitary Transportation of Food Sanitary Transportation of Food Proposed Rule Compliance Requirements “Proposed § 1.908(b)(1) would assign this responsibility to the shipper because we have tentatively concluded that the shipper is in the best position to know the characteristics of the food to be shipped that may necessitate the provision of specific features for the vehicle or transportation equipment.”
Sanitary Transportation of Food
Sanitary Transportation of Food Proposed Rule Compliance Requirements “The proposed rule would establish requirements for carriers to develop and implement written procedures subject to recordkeeping that specify its practices for cleaning, sanitizing, and inspecting vehicles and transportation equipment as required by this rule.�
Sanitary Transportation of Food
Sanitary Transportation of Food Proposed Rule Compliance Requirements “Proposed § 1.910(b) would require that carriers establish and maintain records that document required training of personnel. Such records would be required to include the date of the training, the type of training, and the person(s) trained. These records would be subject to the records requirements of proposed § 1.912 (discussed in section III.G).”
Sanitary Transportation of Food
Sanitary Transportation of Food Proposed Rule Compliance Requirements “Given the importance of adequate training to the conduct of sanitary transportation operations by carriers, we tentatively conclude that this proposed rule should also require that carriers maintain records documenting that they have provided the required training to their personnel to enable the agency to verify compliance with the training requirement through inspection and records examination.�
Food Safety Modernization Act
So what do I do now? •The Food Safety Modernization Act is evolving. It is important to understand how the compliance requirements will affect your customers and you. •Private Fleets visit with their Quality Assurance Department and determine how to help with these new FSMA compliance requirements. •For Hire Fleets visit with your Food Facility customers and understand how they intend to be in compliance with these requirements. What do those requirements mean to your fleet?
S7 Mini-tech Inside the Trailer: Specification Considerations to Help Keep Things Clean
Charlie Fetz VP Design and Development
• Trailer specs: –Reducing damage –Improving “cleanability” • Other considerations?
Floors and Gutters
Duct Floor
Cargo Floor
Floors and Gutters • Match the top floor and crossmember spacing to the expected load and duty cycle • Inspect often for damage, don’t let a minor repair turn into a big problem (or spec heavier) • Don’t use corrosive chemicals to clean or brighten
Scuffband (Wearband) and Liner
Scuffband (Wearband) and Liner
Air Delivery System
Interior Accessories • Logistic track • Overhead door track protectors • Pallet stops • Gutter fillers or dock plates • Evaporator guards
Other Considerations • Consult the experts on specs that will work for you, that’s part of their job! • Inspect your trailers (others will be) • Maintain your trailers to help avoid problems – Temperature records are a must – Maintenance records will help you too!!
Thanks!!
2015 TMC Annual Meeting Your Trailer – Clean It! Michael Gordon Vice President American Truck Wash Systems
PROPER PROCEDURES FOR TRAILER CLEANING • • • • • • •
Trailer Cleaned/Swept Out of all Large Debris NSF - USDA Compliant – A 1 Rated Chemicals Temperature of Water for Correct Washout / Chemical Requirements Examine for any Trailer Damage / Problems Examine Bulkheads and Reefer Covers Documentation Process for Traceability Examine after Wash Process
TRAILER CLEANING AND SANITIZING SOLUTIONS
MANUAL
VS
AUTOMATIC
MANUAL WAND WASH PROS: • • •
Inexpensive Capital Costs Small Fleet Capabilities Portable
CONS: • Workmans Comp Claims / OSHA Violations • Hazardous Environment / Proper PPE for Chemical (Refer to MSDS) • Wash Cost Control and Reliability • Capturing Wash Water with a Portable System • Cold Climates (Portable)
AUTOMATED INTERIOR WASH SYSTEMS PROS: • • • • • • • •
CONS:
Cleans and Sanitizes a 53’ Trailer • Increased Capital Expense in less than 2 Minutes • Location for Equipment Reduce FTE’s and Increase (FOOTPRINT) Throughput Reduce Work Comp Claims and OSHA Violations Control all Wash Costs Datalogging and Reporting Capability for Traceability Reliable, Consistent Wash Results Decreased Cost Per Wash Meets all FDA / USDA Regulations
PROPER DISPOSAL OF WASH-WATER STORM WATER: -Stormwater runoff is generated when precipitation from rain and snowmelt events flows over land or impervious surfaces and does not percolate into the ground.
GROUND WATER: -Groundwater is the water located beneath Earth's surface in soil pore spaces and in the fractures of rock formations. A unit of rock or an unconsolidated deposit is called an aquifer when it can yield a usable quantity of water.
SURFACE WATER: -Surface water is water on the surface of the planet such as in a stream, river, lake, wetland, or ocean. It can be contrasted with groundwater and atmospheric water.
IMPROPER WASH-WATER DISPOSAL
PROPER DISPOSAL OF WASH WATER WASH WATER / WASTE WATER: -Wastewater, also written as waste water, is any water that has been adversely affected in quality by anthropogenic influence.
DISPOSAL TYPES: • • •
Sanitary Sewer / Treatment Plant Septic System Drain Field / Leach Field
The National Pollutant Discharge Elimination System (NPDES) program sets requirements and issues permits for the types of discharge. (Please refer to all State and Local Codes)
PROPER WASH-WATER DISPOSAL
PROPER CHEMICALS • • • • •
SOAP / DETERGENT CLEANERS NSF/USDA-A1 Approved General Cleaning Agents for all Surfaces in all areas Bio-dregradable Envrionmentally Safe Non-Chlorinated
• • • • • • •
SANITIZERS NSF/USDA-D1 Approved Safe on all Surfaces Does Require a Fresh Water Rinse NSF/USDA-D2 Approved Safe on all Surfaces Does not Require a Fresh Water Rinse Approved for High Pressure / Low Pressure Applications
*CHECK WITH TRAILER MFG*
Sanitary Transportation of Food Proposed Rule Compliance Requirements “The proposed rule would require that shippers specify to carriers in writing the sanitary requirements for a vehicle or transportation equipment to be provided for all food subject to this proposal and the temperature requirements for foods subject to temperature control requirements. “
Considerations when Designing a Trailer Sanitation Plan Tom Jones Publix Super Markets
Our Fleet Total Dispatches – 8
Total Drivers – 1092 Total Tractors – 527 Total Trailers – 2,800 Total Deliveries (2014) – 1.2 Million Total Miles Driven (2014) – 60.3 Million
Consistency • Sanitation Schedule •
Frequency of wash
•
Levels of wash
• Trailer Inventory •
Trailer identification
•
Trailer location
Operational Efficiency • Logistics •
Where/How will your operation take place?
• Site Layout •
Trailer flow, organization, multiple washing stations
• Mobile Washing Equipment •
Decreases down time in-between washes
• Backup Equipment •
Safety net for unexpected issues
Efficiency
Keep it Clean • Training •
Train all associates in Current Good Manufacturing Practices (CGMPs)
•
Execute & document detailed training for sanitation personnel
• Preventative Measures •
Regular trailer maintenance
•
Keep trailer doors closed in yard
•
Effective pest control
•
Clean warehouse equipment
Records & Tracking • Detailed Wash Records •
Inspection checklists
• Electronic Tracking System •
Ease of access
•
Historical archives
• KPI Reporting •
Compliance
•
Performance
•
Total Cost
Questions?